TC09595 - [2025] UKFTT 00894 (TC)

For the reasons above, we have concluded that the payment of the security bond by the cadet to APL is consideration for the taxable supply of training to the cadets and therefore liable to VAT. However, given the s 85 VATA agreement between the parties, 27.4% of the amounts paid to APL by the cadets should be treated as training which took place outside the UK and therefore outside the scope of VAT.

Therefore, we allow the appeal in part to take account of the adjustment to reflect the agreement under s 85 VATA but in all other respects the appeal is dismissed.

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.