This case concerns car safety tests carried out by The Towards Zero Foundation (TZF) and whether these represented a non-business activity.
TZF is a charity with the objective of achieving zero road traffic fatalities through the operation of New Car Assessment Programmes (NCAPs). In each jurisdiction where an NCAP is established TZF anonymously purchases and crash tests individual models of cars manufactured in that jurisdiction. TZF will then publicise the results. The results often encourage the car manufacturers to improve the safety features of their vehicles and pay for further testing by TZF. The initial anonymous purchase and testing of vehicle is funded by TZF. The majority of costs incurred by TZF are non-UK costs but as they are established and operated from the UK it incurs UK VAT on overhead running costs, particularly in relation to marketing and consultancy costs.
Source Constable
