An issue that often crops up with zero-rating passenger transport in a boat, vehicle or aircraft for 10 or more people is how that is determined. VAT Act 1994 schedule 8 group 8 item 4 speaks about something that has been “designed or adapted to carry not less then 10 passengers”. In my case of Cirdan Sailing Trust v Customs & Excise  UKVAT V18865 it was established that each word, designed or adapted, has a place and one looks at the current physical state of the boat. Cirdan was cited with approval in British Disabled Flying Association v HMRC  UKFTT 743, where aircraft were adapted for special use by disabled persons.
Tax Barrister, Accountant