Considers "R v Customs and Excise Commissioners ex p Greenwich Property Ltd" where Customs and Excise (C) claimed that a zero-rated certificate for VAT should not have been issued to Greenwich Property, a wholly owned subsidiary of the University of Greenwich, for its student residences because it did not provide summer vacation accommodation itself but had granted a licence to Avery Hill, the company which had constructed and maintained the buildings under a PFI agreement, to do so. At judicial review, however, it was ruled that if C wanted to exclude the use of a third party it should have said so in the Concordat Para 37a, which permits educational institutions to issue zero-rating certificates where there is a non-qualifying summer vacation use. This had not been done and consequently it was held that to not apply the concession would be unfair and unlawful. Case Law