This is an appeal against an assessment of £164,866 made on the basis that the appellant made standard-rated supplies of services which are properly characterised as supplies 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’). Essentially, the contractual arrangements may be summarised as follows:
(1)â¯â¯â¯â¯â¯â¯â¯â¯â¯â¯Contracts between the appellant and various doctors.
(2)â¯â¯â¯â¯â¯â¯â¯â¯â¯â¯A contract between the appellant and A&E.
(3)â¯â¯â¯â¯â¯â¯â¯â¯â¯â¯Contracts between A&E and NHS Trusts.
The contractual framework in this appeal was common ground, to the extent that the appellant contracts to supply A&E, and A&E contracts to
