Fareham College – FTT – education – closely related supplies – whether supplies from training restaurant exempt – yes – whether supplies from training beauty salons and performing arts centre exempt – no – part taxpayer win and part loss
The taxpayer is a FE/HE College which offers catering, hair and beauty and performing arts courses. Students gain practical experience in a realistic environment by working in the training outlets. The key question was whether the income generated was exempt. HMRC said it was taxable arguing that the basic purpose was to obtain additional income through transactions in direct competition with commercial enterprises.
Source KPMG
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