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 an eligible body in Note (1) Group 6 breaches the principle of fiscal neutrality –
Item 5B Group 6 – whether the 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 was a college of a UK university and qualified as an eligible
body by virtue of Note 1(c) – 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 – appeals dismissed
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