Summary 
 
The appellant carried on the business of a pharmacy and dispensed prescriptions including private prescriptions. This appeal concerned whether the appellant was entitled to zero rate certain of the supplies it made of prescription medicines which were dispensed on private prescriptions.  

Background 

HMRC assessed the appellant to VAT and interest in the sum of £156,782.41 by a notice dated 15 April 2016.  

In 2007 the appellant entered into a contractual relationship with Hexpress Limited (Hexpress), a Guernsey company and a Mauritian company called Gloxinia which continued until 2013. Hexpress and Gloxinia contracted with a UK company, E-med Private Medical Services Limited (E-med) to carry out the medical screening services. E-med employed the doctors