Facts
Facts
Corporate structure
APL which was incorporated in 2004 was, until the end of March 2025, a subsidiary within a group of companies, the L3 Harris Group, that provides training to airline pilots. APL was 100% owned by L3 A&AT which itself was owned by L3 CTS. L3 A&AT was formed to acquire the business of CTC Aviation Group plc (“CTC”) which it did in May 2015 through the purchase of shares in CTC Aviation Holdings. APL was previously part of CTC, which included CTC McAlpine Ltd and Airline Recruitment Limited.
Airline Recruitment Limited was the entity initially responsible for administering the Sponsored Training Programme, a role which was essentially taken over by APL following its incorporation.
- Heading
- Introduction
- Evidence
- Facts
- Sponsored Training Programme
- Contractual Arrangements
- Contact with HMRC
- Judicial Review
- Issues
- Whether security bond consideration
- Whether Halifax abusive
- Redefinition - whether credit should be given for VAT payments on placement fees
- Whether there was a s 85 VATA agreement
- Whether the place of supply of was the UK or New Zealand
- Conclusions
![TC09595 - [2025] UKFTT 00894 (TC)](https://backend.juristeca.com/files/emisores/logo_7HSuEAV.png)