Revenue Legislation Services
This information leaflet which sets out the current practice at the date of its issue is intended for guidance only and does not purport to be a definitive legal interpretation of the provisions of the Value-Added Tax Act 1972 (as amended).
Membership fees, annual subscriptions from members of member-owned golf clubs are exempt, as are capital levies paid by members. However, certain non-member golf turnover such as income from green fees of member-owned golf clubs are liable for VAT. In addition, all income from State/local authority and commercially owned courses are taxable.
Golf facilities includes driving ranges and par 3 golf but not 'Pitch and Putt'.
2. Member-owned clubs
Where the total annual taxable income (i.e. green fee and other golf turnover) from the provision of facilities for taking part in golf in a member-owned golf course exceeds the specified limit (€37,500 in any continuous period of twelve months), it will be liable for VAT at the reduced rate.
Taxable income includes green fees, other pay-as-you-play income, short-term membership subscriptions and corporate subscriptions. The excess in competition fees paid by a non-member over the amount paid by a member is regarded as a green-fee and is also taxable.
Individual membership subscriptions for member-owned golf clubs are exempt from VAT as also are the fees charged to Pavilion or Social members.
For VAT purposes a member is defined as a person who, having paid the annual subscriptions, is entitled to play golf on the course without further payment for at least 200 days per year. If a member makes an additional payment for a further benefit (e.g. the right to play on days not covered by the terms of his membership), that payment is liable for VAT.
3. Election to register
A golf club can elect to account for VAT in respect of its non-member golf turnover if it is below the specified limit. An application for such an election should be submitted to your local Revenue District.
4. State/local authority owned and commercial golf courses
4.1: State or local authority owned golf courses are also required to register and account for VAT. If a local authority operates a number of courses the specified limit relates to the combined golf turnover of all its courses. While one VAT registration will cover all golf courses operated by a local authority, the body in question may opt for separate registration for each course if this is more convenient.
4.2: Commercial golf courses are required to register and account for VAT where the total turnover exceeds or is likely to exceed €37,500. All income, including any membership fees, annual subscriptions and levies are subject to VAT.
4.3: Income received by such golf clubs, including from share issue, which confers an entitlement on purchasers to avail of the facilities of the club are taxable.
5. Apportionment of inputs
Where a golf club is made taxable in respect of its non-member golf income it may deduct VAT on its inputs to the extent of its taxable activities. As the income from the golf club will be derived from both taxable (e.g. bar receipts, non-member green fees etc.) and exempt activities (e.g. membership fees), it will be entitled to apportion VAT incurred on its expenditure for the purposes of claiming input credit. Expenses directly related to taxable activities will be allowed full deductibility of VAT, while expenses directly related to exempt activities will not be allowed any deductibility. Apportionment will arise in the case of dual-use inputs where activities with an element of both taxable and exempt are involved.
Examples illustrating the changes in relation to registration and accounting for VAT by member-owned golf clubs are given in Appendix I.
6. Sporting facilities provided by non-profit making bodies
The provision of facilities for taking part in other sports and services closely related there to by non-profit making organisations is exempt from VAT. However, the Revenue Commissioners may determine that the provision of such facilities by the State, a local authority or a non-profit making organisation is liable for VAT at 13.5% where the annual turnover for such activities exceeds or is likely to exceed the specified limit, if:
- the exemption of those services creates or is likely to create a distortion of competition which puts a commercial supplier of similar services at a disadvantage, or
- the service is actually a commercial enterprise
Where the Revenue Commissioners are satisfied that such conditions apply they will issue a determination in writing to the body concerned giving notice of the decision.
For further information on VAT and other Sporting Activities, please refer to VAT Information Leaflet 'Sporting Facilities'. Enquiries regarding any issue contained in this Information Leaflet should be addressed to the Revenue District responsible for the taxpayer's affairs. Contact details for all Revenue Districts can be found on the Contact Details page.
This leaflet is issued by
VAT Interpretation Branch,
Indirect Taxes Division,
Summary of VAT Position in the Case of Member-Owned Golf Clubs (Assume non-golf turnover = A, and non-member golf turnover = B)
Already registered for VAT in respect of its turnover from non-golf activities: if its non-member golf turnover exceeds or is likely to exceed the specified limit it must account for VAT at the reduced rate on such turnover, in addition to accounting for VAT on its turnover from non-golf activities.
Hence, already registered for A, and B exceeds the specified limit; VAT on B must be accounted for in addition to A.
It is not obliged to account for VAT on its non-member golf turnover if less than the specified limit but it must continue to account for VAT on its non-golf turnover.
Hence, already registered for A, and B less than the specified limit; not obliged to account for VAT on B. but must account for VAT on A.
Not already registered for VAT, in respect of its turnover from non-golf activities, because that turnover is below the threshold for registration: if its non-member golf turnover exceeds or is likely to exceed the specified limit, it must register and account for VAT on both its non-golf turnover and its non-member golf turnover,
Hence, not registered for A, and B exceeds the specified limit; must register, and account for VAT on both A and B.
If its non-member golf turnover is less than the threshold, it is not required to register, even though the combined total of non-golf and non-member golf turnover exceeds the specified limit.
Hence, not registered for A, and B less than the specified limit; not required to register, even if A + B exceeds the specified limit.