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HMRC internal manual

VAT Education Manual

HM Revenue & Customs
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Group 6 Item 1 Education, research and vocational training provided by eligible bodies: what is education?: sports and gym coaching

In the sports sector, education includes classes that are led and directed, rather than merely supervised. For example, a local authority gymnasium will normally supply instruction in the use of equipment and in warm-up techniques, particularly when a person first enrols. This instruction, together with any assessment that may form part of it, is education.

Mere participation in an event is not education. Where, for example, an individual uses the gym in a separate session where no instruction takes place, this is not education. Similarly, leisure sessions in a swimming pool without instruction taking place are not the provision of education.

In both these cases, members of staff are likely to be present for supervision on health and safety, and insurance grounds but not to provide instruction. Under these circumstances, the charge is for the admission and use of facilities and is thus normally liable to VAT unless it is exempt under

* Schedule 9, Group 1, Item 1 (land) or
* Schedule 9, Group 10, Item 3 (services closely linked-with and essential to sport or physical education)

of the VAT Act 1994.