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HMRC internal manual

VAT Valuation Manual

Specific applications: School Photographers

Sales by photographers to schools

  • Sales to VAT registered bodies - Where the contractual arrangements provide that the supply of photographs is to a school or other body, which is registered or registrable for VAT, for onward and independent sale to the parents/pupils, that body must continue to account for VAT on the value of sales to the parents/pupils.
  • Sales to unregistered bodies - Where the contractual arrangements provide that the supply of photographs is to a school or other body, which is not registered for VAT, the photographer must continue to account for output VAT on the value of sales by schools or other bodies to the parents/pupils if he has been issued with a Notice of Direction under paragraph 2 of Schedule 6 to the VATA 1994. If no Notice of Direction has been issued, the photographer should continue to account for VAT on the value of the sales to the unregistered school or other body.
  • Effect of the changes on existing Notices of Direction - Notices of Direction have only ever required photographers to account for VAT on the final selling price charged by unregistered persons to the parents/pupils e.g. where the photographer sells to a school not registered for VAT and the school in turn sells the photographs on to the parents. Notices of Direction have never required photographers to account for VAT on the final selling price to parents/pupils where the intermediate sale is to a VAT-registered person such as an LEA. However, it may be the case, following the complex history of this subject, that some photographers have in error been accounting or been required to account for VAT on the final selling price charged by a VAT-registered school to parents/pupils. In such cases the photographer should only account for VAT on the price charged to the LEA or VAT-registered school.

Note: the above changes only affect school photographs. There are no other changes in respect of the arrangements for accounting for output VAT on LEA schools’ private fund activities.