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VAT in paradise rather than in the UK

Should a Grenadian university register for VAT in the UK, because the teaching for its medical degree is conducted in the UK? HMRC thought it should, the FTT disagreed.

19th Mar 2021
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St George’s University (SGU)

SGU is incorporated in Grenada as an independent school of medicine under a government charter. It has a large campus, being the only university, and is a major employer.

It offers a four-year medical degree (MD) over ten terms. The first five terms involve basic science over a two-year period and SGU partners with the University of Northumbria (UNN) under a global scholarship programme (GSP) that allows students to study in the UK.

The next five terms over a two-year period involve clinical training conducted under an agreement between SGU and various UK teaching hospitals. The MD course  is internationally accredited and recognised including by the UK’s General Medical Council.

What were the issues?

The parties in the case before the FTT: St George’s University Ltd v HMRC (TC07999) agreed on four questions, although if the first two fell in favour of SGU then the other two would fall away.

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Replies (3)

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Jason Croke
By Jason Croke
19th Mar 2021 14:50

Nice article, interesting case.

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By vstrad
22nd Mar 2021 13:45

Thank you, James. I notice Grenada became Granada halfway through :-)

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Replying to vstrad:
rebecca cave
By Rebecca Cave
22nd Mar 2021 15:21

I've fixed that typo

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