The appeal concerned whether VAT should have been charged on the supply of car parking by Northumbria Healthcare NHS Foundation Trust, a case which had implications for 50 other related cases with total tax exposure of up to £70m. In a unanimous decision, the Supreme Court has ruled in favour of HMRC, deciding that the VAT charge was correctly made.

The Trust operates 14 hospitals and provides pay-and-display car parking at up to £6 for 24 hours, and made a claim for a rebate of for £267,443 in overpaid VAT for a three-year period from 2013 to 2016. It argued that it was ‘acting as a public authority’ under the ‘special legal regime’ (SLR), which meant it should not have been treated as a ‘taxable person’.

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