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HMRC internal manual

VAT Trade Unions and Professional Bodies

From
HM Revenue & Customs
Updated
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Trade unions and professional bodies: Item 1(c) branch of knowledge / professional expertise: General

“Item 1(c)” of “Group 9” contains two different bases upon which an organisation may qualify for exemption.

  • The body’s “primary purpose” must either be

    • “advancing a particular branch of knowledge”, or
    • “fostering” its “members’ professional expertise”.

The “primary purpose” criterion is common to both of these heads of exemption, as is a requirement that the knowledge or expertise should be “connected with the past or present professions or employments of the members”.

  • In addition, “Note (4)” to the group stipulates that the association must restrict its membership “wholly or mainly” to individuals whose past or present professions or employments are “directly connected with the purposes of the association”.

However, following the ECJ decision in the Institute of the Motor Industry (referred to in VTUPB1200) HMRC takes the view that membership need not be restricted to individuals.

VTUPB5200 and VTUPB5300 set out the criteria particular to each of the heads of exemption; VTUPB5400, VTUPB5500 and VTUPB5600, the criteria applicable to both.