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St George’s University Ltd v HMRC

In St George’s University Ltd v HMRC [2021] UKFTT 13 (22 January 2021) FTT ruled that the place of supply of educational services is where the supplier belongs.

The appellant (SGU) was a university based in Grenada West Indies. It offered eligible students a four-year course (‘the MD course’) leading to a medical degree. Students had the option (‘the GSP option’) of completing the first year of the course in the UK at the University of Northumbria in Newcastle (UNN). They also had the option (‘the CTP option’) of completing either or both of the final two years which took the form of clinical training at NHS teaching hospitals in the UK. 

In respect of the UK-based elements of the course (i.e. the GSP and CTP options) HMRC took the view that: SGU was making supplies of education in the UK; and SGU was not...

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