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Bell’s College Ltd (TC4369)
A private company made supplies of education to overseas students.
HMRC assessed output tax of £207 750 made in the VAT periods ending February and May 2011 on the basis they had been incorrectly treated as exempt rather than standard rated.
The taxpayer claimed to be exempt under VATA 1994 sch 9 group 6 because it was a school in accordance with Education Act 1996.
The Revenue disagreed because no full-time education was on offer.
The taxpayer also argued it was a hall of a university because it held various agreements with higher education institutes including Manchester Metropolitan University and Liverpool John Moores University.
HMRC rejected the claim on...
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