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HMRC internal manual

VAT Education Manual

Group 6 Item 2 Private tuition and tutorial colleges: tuition delivered partly by the individual teacher and partly by someone else

In principle, private tuition is exempt when supplied by either a sole proprietor or any member of a partnership. The exemption does not extend to instruction delivered by anyone employed or engaged to help. In these circumstances, the sole proprietor or partnership may opt to use any fair and reasonable method to apportion their supplies between exempt and taxable elements.

If this is impractical, they may treat all their supplies of tuition as taxable, regardless of who actually delivers it.

If a sole proprietor or partnership employs or engages others in a non-teaching capacity, this has no effect on the liability of the tuition they themselves supply.