Conclusions
Disposition
For the reasons stated we find that the Appellant’s supplies do not meet the conditions for exemption under Item 4 as closely related to supplies of medical care. The consideration received from its customers was received including VAT.
HMRC were therefore correct to assess the Appellant for VAT in the Relevant Period at the appropriate VAT fraction of the consideration received on which the Appellant had not accounted for VAT. We are satisfied that the Assessments, after review, have been calculated on that basis.
Right to apply for permission to appeal
This document contains full findings of fact and reasons for the decision. Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009. The application must be received by this Tribunal not later than 56 days after this decision is sent to that party. The parties are referred to “Guidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)” which accompanies and forms part of this decision notice.
Release date: 07th NOVEMBER 2025
- Heading
- Introduction
- Background
- Relevant law
- evidence and findings of fact
- Application to admit additional documents
- Agreed facts
- Documentary evidence
- Mr Odong’s evidence
- Findings of fact
- Legal requirements for exemption as a closely connected supply
- State regulated institution
- Closely related
- Conclusions
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