The Tribunal having demined that there is a service, the next
issue for determination would" be whether and if so, when did the
service become taxable?

The Appellant filed its Memorandum of Appeal on 6th May 2013
together with their Statement of Facts. The Appellant prayed that
the Respondent refrain from charging it tax on conservation fees
and sought that the assessment be adjusted, The Appellant also
prayed for directions to be provided on clear guidelines on
conservation fees and the same be gazetted. The Appellant sought
period of at least one year to reorganize their operations so as to
Judgement: Tax Appeal No.116 of 2015 Page 1 be in a position to implement the imposition of VAT on
conservation fees in the event the Tribunal dismissed their Appeal

The Tribunal having entered a finding that the service provided was
not a business and therefore did not attract VAT, the Appellant was
well within their right to appeal the decision of the Respondent and
consequently, it