This was an appeal from the First-tier Tribunal (FTT) by the three appellants. The issue in this appeal was whether certain supplies of education made by the appellants should have been treated as exempt for VAT purposes by virtue of Article 132(1)(i) of Council Directive 2006/112/EC (the Principal VAT Directive, or PVD) or VATA 1994, Sch 9, Group 6.â¯
The appellants were providers of higher education. The appellants considered that all or some of the supplies made by them should have been treated as exempt for the purposes of VAT. The respondents (HMRC) disagreed and issued various decisions and assessments for VAT relating to supplies made by the appellants in the period 1â¯December 2012 to 6 August 2017. In 2019, the appellants appealed to the FTT.
The appellants argued on four points:
(1) whether the UK's implementation of Article 132(1)(i) PVD breached the EU principle of fiscal neutrality because the appellants&
