Summary 

The appellant is a university based in Grenada, West Indies. It offers a four-year medical degree course. Students on the course can opt to complete parts of the course in the UK. Some students opt to spend the first year of the course in the UK on the Keith B Taylor Global Scholars Program (‘GSP’) provided at the campus of the University of Northumbria in Newcastle (‘UNN’). Some students also undertake their third and/or fourth year clinical training element of the course in the UK (‘the UK Clinical Training Programme’) at teaching hospitals run by various NHS Trusts. HMRC ruled that the appellant was making taxable supplies of education in the UK and should be registered for VAT. 

Background 

The appellant and HMRC agreed that the appeal raised the following issues: 

• Who