TC09595 - [2025] UKFTT 00894 (TC)

Whether the “security bond” paid by the cadets to APL was consideration for the supply of training, and therefore liable to VAT;

Alternatively, whether the STP arrangement gave rise to an abusive result under the principles set out in Halifax Plc v Customs and Excise Commissioners (C-255/02) and therefore, needs to be redefined;

If the security bond payable by the cadets to APL is either consideration for the supply of training or if that arrangement is found to be abusive, how should the arrangement be redefined and whether any assessment should be reduced to take into account VAT payments made on the placement fees paid by the Sponsor Airlines to APL;

Whether the parties made an agreement under s 85 VATA such that the assessments must now be treated as varied to exclude VAT assessed in relation to supplies of training purported to have been made in New Zealand or otherwise outside the UK; and

If, the “security bond” is consideration for the supply of training, whether the place of supply of the training was the UK or New Zealand and outside the scope of UK VAT.