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HMRC internal manual

VAT Education Manual

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HM Revenue & Customs
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Group 6 Item 1 Education, research and vocational training provided by eligible bodies: eligible bodies: teaching English as a foreign language

Liability of supplies of tuition

All supplies of tuition in English as a foreign language (TEFL / EFL) by commercial providers are exempt under item 1 of Group 6 of Schedule 9 of the VAT Act 1994 (see VATEDU15000). The exemption applies because any supplier of EFL tuition is an eligible body falling within the description of Note (1)(f) of Group 6.

Following the judgement of the Court of Appeal in Pilgrims Language Courses Ltd [1999 STC 874] we now accept that this includes all elements integral to the course. This means elements that are held out for sale as such and by means of which the provider aims to promote fluency in the use of the English language. For example:

  • sports and games;
  • recreational activities;
  • sightseeing; and
  • social activities.

Any separate supplies of closely related goods and services are also exempt, providing they meet the conditions set out in VATEDU50000.