Colchester Institute v Revenue & Customs (VAT - INPUT TAX : Business purposes) [2018] UKFTT 479 (TC) (15 August 2018)

Colchester Institute v Revenue & Customs (VAT - INPUT TAX : Business purposes) [2018] UKFTT 479 (TC) (15 August 2018)

Payments made by EFA and SFA to CIC do not amount to consideration for the supply of services; the provision of grant-funded education and vocational training is not an economic activity for VAT purposes and is outside the scope of VAT. There is no entitlement to input VAT recovery in these circumstances.

Citation
[2018] UKFTT 479 (TC)
Parties
Appellant: CIC; Respondent: HMRC
Jurisdiction
United Kingdom
Judgment Date
15 August 2018
Procedural Posture
Tax Appeal / Final Judgment
Outcome
appeal dismissed
Legal Topics
Economic Activity, Consideration, Education Funding, VAT Exemption, Input Tax Recovery
Tax Law VAT Economic Activity Consideration Education Funding VAT Exemption Input Tax Recovery

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Parties

CIC

Appellant

HMRC

Respondent

Procedural Posture

Tax Appeal / Final Judgment

Legal Issues

  1. 1 Whether grant-funded education/vocational training by further education colleges is an 'economic activity' for VAT purposes
  2. 2 Whether funding by EFA and SFA constitutes consideration for supplies
  3. 3 Entitlement to input VAT recovery

Ratio Decidendi

Payments made by EFA and SFA to CIC do not amount to consideration for the supply of services; the provision of grant-funded education and vocational training is not an economic activity for VAT purposes and is outside the scope of VAT. There is no entitlement to input VAT recovery in these circumstances.

Court Disposition

appeal dismissed

Orders

  • CIC's appeal is dismissed
  • No entitlement to input VAT recovery