Value added tax – Exemptions. The Upper Tribunal (Tax and Chancery Chamber) (the tribunal) dismissed the appeal by St Andrew's College, Bradfield, against a decision of the First-tier Tribunal (Tax Chamber) which had decided that the supplies of sports services by the college's subsidiary companies did not qualify for exemption from VAT under s 31 of and item 3 of Group 10 of Sch 9 to the Value Added Tax Act 1994, as supplies by an eligible body of services closely linked with and essential to sport or physical education. The tribunal decided that exemption should not be afforded in a case where the constitution of the relevant body, as it stood at the relevant time, would permit distribution of profits to a body which was not an eligible body even if, on the facts of the case, distributions could in practice be distributed only to an eligible body.