The Yorkshire Agricultural Society, a charitable company that runs the annual Great Yorkshire Show, disputed an assessment of £90,776 in VAT payments for the period 12/17, and a refusal by HMRC to allow a net VAT repayment of £201,949, which the appellants argued should have been treated as exempt for the purposes of fundraising.

The case concerned the two appeals, one against the assessment, the other against the refusal to allow a claim for overpaid tax, which the Society argued was submitted out of time.