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HMRC internal manual

VAT Trade Unions and Professional Bodies

Trade unions and professional bodies: Item 1(c) branch of knowledge / professional expertise: Professions or employments directly connected

“Note 4” excludes associations from exemption under “Item 1(c)” unless the membership is restricted “wholly or mainly to individuals whose present or previous professions or employments are directly connected with the purposes of the association”.

There are two separate requirements within this note -

  • being restricted to “individuals”, and
  • having the “employment” connection.

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.

You should apply the same 75% criterion that we apply in “Item 1(b)” cases - see VTUPB4300.