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Metropolitan International Schools v HMRC

Distinguishing between supplies of education and supplies of manuals

In Metropolitan International Schools v HMRC [2015] UKFTT 517 (2 October 2015) the FTT found that Metropolitan was providing a single zero-rated supply of manuals.

Metropolitan provided distance learning trade courses. It contended that its service was the provision of manuals (books for VAT purposes) and that any other elements of its service were ancillary so that it provided a single zero-rated supply. HMRC had changed its view following the House of Lords’ decision in College of Estate Management [2005] UKHL 62 (CEM) and considered that Metropolitan’s single service was the supply of non-exempt education.

The FTT found that the facts could be distinguished from CEM. In CEM the college employed 100 staff including academic staff who undertook the assessment of students with written assignments provided them with face to face teaching and prepared...

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