UT/2024/000002 - [2025] UKUT 00188 (TCC)

For the reasons set out above, none of the grounds, that the FTT erred in law, are made out. As the Appellant accepts that if the FTT’s decision that there was a single supply was found to be correct it accepts that the characterisation of such supply is, as the FTT found, that it is taxable (although it disputes the FTT’s reasoning on the characterisation of the supply - we deal with this below) the dismissal of these grounds is sufficient to dispose of CBNA’s appeal. Nevertheless in recognition of the full and detailed argument we heard on the exemption issue, which the FTT dealt with too (on an obiter basis), we shall address that issue in the following section albeit briefly.