In short, our view is no. These fees are, ultimately, a personal expense of the client's family and it is very unlikely you would be able to argue that these are being bought and paid for by the business for its business purposes. You might be able to argue business purpose if it was an employee incentive available not just to owners / directors, but HMRC would generally then seek an output tax charge that would negate any VAT recovery. This would be on either the onward supply (including under salary sacrifice) or the deemed onward supply (where given to the individual free of charge).
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