VAT and student loan funds movements

payrollpro

Would love to hear what members make of this one.

Four parties, A, a university, B a professional body, C an intermediary and D a private company providing services to all three. A receives student loan (SL) funding in accordance with the statutory rules and retains a sum to pay for A's registration and administration process. A significant proportion is paid to B to fund tutor fees and cost of materials, tutorials etc and the balance is paid to C.

C then distributes this sum 50/50 to B and D resulting in a nil P&L and zero balance sheet.

I am guessing A is exempt (educational establishment, charitable status and processing SL funding leads me to this conclusion). I am guessing the direct payments to B for tutoring etc is also exempt as it is the provision of education services to an exempt body.

I can see that D's services to C are a taxable supply as they are not necessarily an educational service, they are consultancy services in respect of verifying student numbers and reconciling this with the amounts being distributed, however what about B's relationship with C?

Happy to provide more details, but if anyone has any insight I'd be grateful because this one seems so complex it almost looks like it should be an exam question.