TC09595 - [2025] UKFTT 00894 (TC)

Case Number: TC09595

Hybrid hearing at Taylor House, London

Appeal reference: TC/2022/12528

VAT – Procurement of training for pilots – Whether “security bond” paid by trainee pilot was consideration for provision of training – Whether arrangements give rise to an ‘abusive’ result under Halifax principles – If the security bond is consideration for provision of training or Halifax abusive, whether (1) credit should be given for the output tax already accounted for; (2) the parties reached an agreement under s 85 Value Added Tax Act1994; and/or (3) the training that took place in New Zealand falls outside the scope of UK VAT – Appeal allowed in part

Judgment date: 23 July 2025

Before

TRIBUNAL JUDGE BROOKS

TRIBUNAL MEMBER AKHTAR

Between

AIRLINE PLACEMENT LIMITED

Appellant

and

THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS

Respondents

Representation:

For the Appellant: Nicola Shaw KC instructed by Macfarlanes LLP

For the Respondents: Howard Watkinson of counsel, instructed by the General Counsel and Solicitor to HM Revenue and Customs

DECISION