(1) St Patrick’s International College Ltd & Interactive Manchester Ltd v HMRC (2) London College of Contemporary Arts Ltd v HMRC
Tuesday 16 – Wednesday 17 June 2026
(1) By Appellant’s Notice filed on 6 June 2025 and issued on 9 June 2025 the Appellant, HMRC, appeals a decision the Upper Tribunal (Tax and Chancery Chamber) (UT) delivered on 24 March 2025.
Issue: Whether the appellants’ educational services qualified for VAT exemption.
The UT found that the UK lawfully limited the exemption to specified bodies (e.g. universities). Indirect funding via student loans did not qualify. There was no direct obligation on the Secretary of State to pay fees. One of the providers was recognised for teaching English as a foreign language, so those courses could be VAT‑free.
The appeals were dismissed. The UK regime was lawful, student loans do not constitute direct state funding, and VAT exemptions only apply in limited situations.
(2) By Appellant’s Notice filed on 6 June 2025, the Appellants, London College of Contemporary Arts Limited, appeal a decision the Upper Tribunal (Tax and Chancery Chamber) (UT) delivered on 24 March 2025.
Issue: Whether the Appellants’ courses should be exempt from VAT under UK and EU law.
The court held that the VAT rules were applied correctly, student loans don’t count as government funding, and exemptions only apply in limited cases.
Appellant’s Skeleton Argument
Respondents’ Skeleton Argument
View Hearing
Day 1
Day 2