This was an appeal to the Supreme Court where the appellant argued that the education exemption applied to its supplies because it was an eligible body. 
 
The appellant contended that its supplies of education to students in the UK were exempt from VAT because it was a college of Middlesex University (MU). The appellant is a subsidiary of SAE Technology Group BV. Both are part of the SAE group of companies which trades around the world under the name 'SAE Institute' (SAEI). MU is a UK university and has never had any financial interest in any SAE group company. Nevertheless, the relationship between MU and SAEI has been very close and is a reflection of a series of agreements addressing the nature of that relationship, the validation by MU of SAEI programmes of education and the accreditation of SAE group companies.  
 
The appellant appealed against assessments raised by HMRC in respect of its