SAE Education Ltd v HMRC

In SAE Education Ltd v HMRC [2019] UKSC 14 (20 March 2019) the Supreme Court found that a company providing education services in close cooperation with a university could benefit from the education exemption (VATA 1994 Sch 9 Group 6).

SAE provides education in audio and digital media technologies and had ‘gained a significant reputation in that field’. Middlesex University (MU) was a university within the meaning of the VATA 1994 Sch 9 Group 6 item 1 note 1(b). It had never had any financial interest in SAE and no MU employee had ever been a director of SAE. Nevertheless the relationship between MU and SAE was very close. In 1998 SAE and MU had agreed a memorandum of cooperation which provided for the teaching by SAE of Bachelor of Arts degree courses in Recording and Multimedia Arts at specified MU campuses. These courses were...