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Policy paper

Revenue and Customs Brief 9 (2026): VAT liability of supplies of education by alternative providers of higher and further education

This brief updates HMRC’s position on the VAT treatment of supplies of education from alternative providers.

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This brief provides an update on HMRC’s position on the VAT treatment of supplies of education and closely related services provided by alternative providers.

It sets out the implications of the Court of Appeal’s decision in St Patrick’s International College and Others Ltd v The Commissioners for HMRC ([2026] EWCA Civ 852).

You should read this brief if you are:

  • an alternative provider of higher or further education
  • a VAT adviser

Updates to this page

Published 2 September 2026

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