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In St George’s University v HMRC [2021] TC 07999, the First Tier Tribunal (FTT) ruled that the place of supply of educational services by a West Indies' university based overseas, which were undertaken in the UK, was based in West Indies and therefore outside the scope of VAT.

St George’s University (SGU) is a university that is based in Grenada, West Indies.

SGU argued that:

HMRC contended that:

SGU disagreed with HMRC’s decision and appealed to the FTT.

The FTT considered the contractual arrangements and found:

The appeal was allowed.  

Useful guides on the topic

Education & VAT
What rate of VAT applies to education? What sort of services are classed as education? What do you do if your have multiple supplies including education? What cases are there on VAT and education?

Place of supply: services
The place of supply (POS) of a service determines whether the supply is within the scope of UK VAT and whether VAT is payable on that supply.

Place of supply: goods
VAT on goods is determined by the place of supply (POS); whether they are UK based supplies, imports, exports, EU dispatches, or EU acquisitions.

External link

St George’s University v HMRC [2021] TC 07999


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