VCHAR3600 | Business and non-business: Charitable activities: Treatment of welfare services supplied below cost: Is the welfare service available to all distressed people equally?
From HM Revenue & Customs · VAT Charities
This point is touched on in the previous paragraphs. In order to qualify as a non-business activity you will need to be satisfied that the subsidised services are available equally to all distressed persons. This means, to qualify the subsidy must:
be available not only to those people who cannot afford to pay the full rate but also available to those who can afford to do so
not be applied conditionally for example, only during spells of very cold weather or only to persons living in a certain area or a person of a certain age.