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The Appellant (� the College �) appeals against a review conclusion by the Respondents (� HMRC �) dated 23 April 2018 that certain supplies of construction services received by the College do not qualify for zero-rating for VAT purposes.
Article 2 Principal VAT Directive (2006/112/EC) (� PVD �), provides, so far as relevant:
( c ) the supply of services for consideration within the territory of a Member State by a taxable person acting as such; ��
� 1. 'Taxable person' shall mean any person who, independently, carries out in any place any economic activity, whatever the purpose or results of that activity.
Any activity of producers, traders or persons supplying services, including mining and agricultural activities and activities of the professions, shall be regarded as 'economic activity'. The exploitation of tangible or intangible property for the purposes of obtaining income therefrom on a continuing basis shall in particular be regarded as an economic activity.� ��
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