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Neutral Citation: [2025] UKFTT 00460 (TC)
Case Number: TC09497
FIRST-TIER TRIBUNAL
TAX CHAMBER
Taylor House, London
Appeal reference: TC2019/01892
VAT - Whether online maths product involving provision of “assessments” was a supply of exempt examination services within item 3 group 6 schedule 9 VATA 1994 or a supply of standard rated education services – consumer perception test applied - held supply was standard rated
Heard on: 7 and 8 April 2025
Judgment date: 24 April 2025
Before
TRIBUNAL JUDGE DAVID HARKNESS
MR MICHAEL BELL
Between
GENERIC MATHS LIMITED
Appellant
and
THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS
Respondents
Representation:
For the Appellant: Mr Kamran Khokhar, a director of the Appellant
For the Respondents: Ms Olivia Donovan, litigator of HM Revenue and Customs’ Solicitor’s Office
DECISION
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- We decided that the appeal should be dismissed introduction and Summary
- Evidence
- Findings of fact
- Law
- Case law – Best judgment
- Case law – education exemption – Consumer perspective and nature of supplies consisting of more than one element
- Burden of proof
- What is GM’s product?
- Mr Constable’s evidence
- The Barbados Study
- Mr Hunter’s Evidence
- Consumer Perception
- The role of assessments in learning
- Conclusion on the nature of ConquerMaths
- Meaning of “examination services”
- Is an assessment a self-standing concept in Schedule 9 VATA?
- Meaning of “Assessments”
- Consumer perception test
- Alternative test – functional analysis
- Best Judgment
- other matters
- Conclusions