(1) ST PATRICK’S INTERNATIONAL COLLEGE LIMITED (2) LONDON COLLEGE OF CONTEMPORARY ARTS LIMITED (3) INTERACTIVE MANCHESTER LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S 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

Read full decision (1) ST PATRICK’S INTERNATIONAL COLLEGE LIMITED (2) LONDON COLLEGE OF CONTEMPORARY ARTS LIMITED (3) INTERACTIVE MANCHESTER LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Value Added Tax – exemption for supplies of education – Article 132(1)(i) Principal VAT Directive – whether properly implemented by Group 6 Schedule 9 VATA 1994 – whether definition of eligible body in Note (1) Group 6 breaches principle of fiscal neutrality – Item 5B Group 6 – 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 –whether 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

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Published 25 March 2025