Continuing professional education facilitation and portfolio-management fees are taxable where no specific exemption applies.

Paid continuing professional education content used by health care professionals to meet a mandatory professional-body requirement was held taxable because it was not part of a recognised degree curriculum, did not amount to health care service, and the provider was not a clinical establishment or educational institution. The related portfolio-management fee was also taxable because the activity was only liaison and facilitation between professionals, bodies, and content providers, with charges collected and passed on rather than education being imparted. Both exemption claims failed, and the advance-ruling questions were answered against the applicant.

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Issues: (i) Whether paid educational content used by health care professionals or students to satisfy a mandatory requirement of a professional body or institute is exempt from tax. (ii) Whether the fee collected for portfolio management is exempt from tax.

Issue (i): Whether paid educational content used by health care professionals or students to satisfy a mandatory requirement of a professional body or institute is exempt from tax.

Analysis: The service was found to be rendered to health care professionals for continued medical education and record management, not as part of a curriculum leading to a recognised degree. It did not answer the description of health care service, nor did the supplier qualify as a clinical establishment. The activity also did not fall within the exemption meant for an educational institution, as the provider was only facilitating access to accredited content and maintaining records for professional bodies.

Conclusion: The paid educational content is not exempt from tax.

Issue (ii): Whether the fee collected for portfolio management is exempt from tax.

Analysis: The portfolio-management activity was treated as a liaison and facilitation service between health care professionals, professional bodies, and content providers. The charges were collected on behalf of the professional bodies and passed on, while the applicant itself did not impart education. The service therefore did not fall under any claimed exemption.

Conclusion: The portfolio-management fee is not exempt from tax.

Final Conclusion: The applicant's services were held to be taxable, and the advance-ruling questions were answered against the applicant.

Ratio Decidendi: A service facilitating access to continuing professional education and related portfolio management is not exempt merely because it assists compliance with a mandatory professional requirement, unless it squarely falls within a specific statutory exemption.

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