HMRC (Appellants) v Colchester Institute Corporation (Respondents)
Wednesday 11 – Thursday 12 March 2026
By an Appellant’s Notice filed on 11 March 2025 and issued on 14 March 2025, the Appellants appeal a decision in the Upper Tribunal (UT) dated 4 December 2024.
The appeal concerns whether grants received by Colchester Institute Corporation (CIC), a further education provider, constituted consideration for a taxable supply of educational or vocational services.
The First‑tier Tribunal (FTT) had allowed CIC’s appeal because it was bound by an earlier Upper Tribunal decision, CIC UT 2020, which had resolved the same “consideration issue” in CIC’s favour for similar grant‑funded activities. Although the Upper Tribunal was not strictly bound to follow its earlier decision, it would normally do so as a matter of judicial consistency.
In this appeal, HMRC accepted that they would not argue before the UT that CIC UT 2020 was wrongly decided, reserving that argument for an appeal to the Court of Appeal, which would not be bound by the UT’s earlier decision. HMRC therefore accepted that their position required the UT to dismiss the appeal.
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