Mark Glenn, co-founders Mark Sharp and Glenn Kinsey established the company in 2001 with the nature of trade described as ‘hair extensions and medical treatments for folicularly challenged’, which is how the company viewed its main trade as VAT exempt.

Additionally, a letter from a VAT expert submitted in evidence said: ‘For zero-rating to apply under the dispensing provisions referred to in my previous letter, two conditions have to be met: a medical practitioner has prescribed the treatment and payment is made under regulation 20 of the National Health Service (Pharmaceutical Services) Regulations 1992.

‘There is another possibility that zero-rating could be available using the legislation for aids to the handicapped. The definition of handicapped is a person who is chronically sick or disabled. The notes to the relevant legislation state that a medical appliance includes wigs.’

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