The case concerns the VAT education exemption. The taxpayers, private colleges which do not satisfy the domestic conditions for exemption under Group 6 of Schedule 9 VATA 1994, argue that the UK has failed properly to implement the exemption in Article 133(1)(i) of the Principal VAT Directive. They contend that the doctrine of fiscal neutrality mandates that their supplies be treated in the same way as those of universities and further education corporations. HMRC maintain that the UK exemption is consistent with fiscal neutrality, properly understood in the light of European case law on exemptions involving supplier conditions.
Laura appears for HMRC.
