This is an appeal against a decision of the First-tier Tribunal (FTT) that the appellant was not supplying exempt medical care (within the meaning of VATA 1994, Sch 9, Gp 7), but was making a standard rated supply of staff. The appellant contended that it made exempt supplies of medical care.

The issue in this appeal was the nature of supplies made by the appellant to intermediary companies, principally a company called Accident & Emergency Agency Limited (A&E). The appellant had six grounds of appeal which were that: