VAT on club membership

Three years ago I took over as treasurer of a club. It has two sides. A trading side which charges and reports VAT on all transactions and a club side which consists of members paying membership and receiving six magazines in return. Also free entry to an annual show arranged by the trading side. Note the two sides are part of one registered company for tax. The members form local branches but these have no financial connection to the club. The club does provide a third party liability policy for them should they arrange local shows etc. For the club side, in 2000, an arrangement for VAT was made by the accountants with HMRC for VAT on membership. Using apportionment. The annual costs of producing the magazine and administration of the club are deducted from the total membership received as they are zero rated supply. The residual is then considered membership and the VAT element calculated and reported. I first encountered this at the end of 2021, researched it through 2022 and raised a query with HMR at the start of 2023. But have had no reply. From what I can see in various notices in 2001/2002 HMRC made this form of apportionment only for certain organisations. There is a specific notice on this for National Trust. Not the club is not a charity. Also that membership should be considered in its entirety as liable to VAT. I am concerned that we have been under reporting VAT for twenty years. All help and advice would be welcome.

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