The Golden Grove Trust, a registered charity based in Carmarthen which has been restoring a Regency hunting lodge and the surrounding Gelli country park, appealed against VAT assessments issued in 2019. For various reasons, the claims were submitted more than two years after the deadline to appeal.

On 15 November 2017, HMRC wrote to the Trust to conduct an audit of its VAT returns for the period 11/13.

It then issued the Trust with an assessment totalling £92,644 on 7 February 2019 for the VAT incurred on the construction of a café and toilets that the Trust operated.

The tax authority then issued a decision on 5 December 2019, stating that the input tax incurred on constructing the café and toilets were not recoverable.