London School of Accountancy and Management (LSAM) refuted a claim for £781,505 in VAT, which HMRC said the organisation owed when the company went into administration in 2012. The VAT bill related to services invoiced to students but never supplied.

The notice of appeal was submitted more than five months after HMRC’s review conclusion letter. HMRC did not object to the appeal proceeding despite the fact that it had been brought out of time.  

The supplies of tuition were subject to the standard rate of VAT. Students were charged separately for associated course materials – no VAT was charged on the basis that they were zero-rated for VAT purposes.

LSAM entered administration in October 2012 due to financial difficulties and Frost Group Limited was appointed as liquidator.