Tax – Value added tax. The appellant company's appeal against a finding that its supplies of education to students in the United Kingdom were not exempt from VAT succeeded. The Supreme Court held that the scope of Note 1(b) of Item 1 of Group 6 of Sch 9 to the Value Added Tax Act 1994 was not limited to a college, institution, school or hall of an university which was separate from a university but was nevertheless a part of it in a constitutional or structural sense. The appellant's supplies of education to students in the UK were exempt from VAT because it had been and remained a college of Middlesex University.