Between June 2017 and June 2019, the Zoological Society of Hertfordshire approved a plan for Paradise Wildlife Park Limited (PWP) in Hertfordshire to construct a lion enclosure, an outside exhibition called ‘World of Dinosaurs’ and a shop called the Dino Store at Paradise Wildlife Park.

The appellant, PWP classed the work as zero-rated on the basis that it fell within Schedule 8 Value Added Tax Act 1994 (VATA), which provides for the zero-rating of construction services supplied in the construction of a building intended for use solely for a relevant charitable purpose.