(1) ST PATRICK鈥橲 INTERNATIONAL COLLEGE LIMITED (2) LONDON COLLEGE OF CONTEMPORARY ARTS LIMITED (3) INTERACTIVE MANCHESTER LIMITED v THE COMMISSIONERS FOR HIS MAJESTY鈥橲 REVENUE AND CUSTOMS [2025] UKUT 00101 (TCC)
Upper Tribunal Tax and Chancery decision by MR JUSTICE RAJAH and JUDGE GREG SINFIELD on 24 March 2025
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Value Added Tax 鈥� exemption for supplies of education 鈥� Article 132(1)(i) Principal VAT Directive 鈥� whether properly implemented by Group 6 Schedule 9 VATA 1994 鈥� whether definition of eligible body in Note (1) Group 6 breaches principle of fiscal neutrality 鈥� Item 5B Group 6 鈥� whether consideration for courses supplied by two appellants to students who were eligible for student loans was ultimately a charge to funds provided by the Secretary of State 鈥搘hether one appellant which was an eligible body pursuant to Note 1(f) by virtue of teaching English as a foreign language was entitled to exemption for all supplies of education