This was an appeal against two decisions by HMRC.  

Firstly, that the appellant’s supplies of skin care treatments were not exempt supplies of medical services and secondly, that the appellant was required to be registered for VAT from 2007, and £212,897 VAT was due. The appellant appealed on the grounds that her supplies were within the medical exemption and, in the alternative, the assessment was issued out of time. 

Prior to establishing her clinic, the appellant was an intensive care nurse working for the NHS. She worked subsequently for large clinics such as the Harley Medical Group and Transform Medical Group where she was a nurse in the skincare department. 

The appellant is, and has since 2011 been, a nurse prescriber. To qualify as a nurse prescriber, she attended London Metropolitan University for one year (between 2010 and 2011). Her course involved studying the medication that she would be providing