UK Funerals On-Line Ltd – FTT – Repatriation of bodies to other countries – whether exempt funeral care or zero-rated transport – both – therefore zero rated – taxpayer win

UK Funerals On-Line Ltd (UKFO) provides repatriation services for deceased persons from the UK to other countries.
The company argues that its services are zero-rated international transport, as they only transport the body and have no involvement in the funeral arrangements.
HMRC argues that the services are exempt under item 2 of Group 8 of Schedule 9 to VATA 1994, which exempts “The making of arrangements for or in connection with the disposal of the remains of the dead.”
The First-tier Tribunal (FTT) found that UKFO’s services lead directly to the disposal of remains and are connected with arrangements for disposal, falling within the exemption.
However, the FTT also found that the predominant element of UKFO’s supplies is transport, which would be zero-rated.

Source KPMG

Exemption