Zero-rating generally applies to articles which are:

(1)designed as clothing or footwear for young children; and

(2)unsuitable for use by older persons (VATA 1994, Sch. 8, Grp. 16, item 1).

When the VAT legislation was originally drafted there was no relief for children’s clothing. However, pressure was brought to bear so that limited zero-rating was introduced.

‘Young children’: age and height limit

The Act does not define ‘young children’, but the tribunal usually uses an upper age of 14.

HMRC’s policy, following consultation with the British Retail Consortium, is to regard a ‘young child’ as one who:

(1)is less than 14 years of age; and

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