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HMRC internal manual

VAT Taxable Person Manual

Particular trades: part-time teachers, lecturers and examiners - employment status

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Earnings of many part-time staff are chargeable as employment income and those part-time services are therefore outside the scope of VAT. However, where a part time appointment is under a contract for services the fees from it are taxable in principle: for example, where a teacher gives a lecture or a series of lectures but controls the manner and style of their delivery. In cases of doubt or difficulty you should consider the factors listed in paragraph VTAXPER34000.

Please remember that although part-time staff may be treated as employees for their part-time work, their other work may be in a self-employed capacity. For example, they may grant rights in respect of their published works for which they receive royalties. This latter income will be chargeable to tax as trading income and liable to VAT in principle.

Where a lecturer has mainly trading income, the part-time income from lecturing may be treated for Direct Tax purposes as if it were also trading income, irrespective of the terms of the part-time appointment. If it is put to you that a part-time appointment treated as trading income is in fact held under a contract of employment, you should consider all the factors pertinent to the appointment using the guidance in paragraph VTAXPER34000.