In Essex International College Limited v HMRC [2018] TC06343, the First-Tier Tribunal (FTT) found that the College provided a  VAT single supply of standard rated education. It was not an eligible body providing exempt education and it could not separate the books into a zero-rated supply.

  • The College is a private limited company and distributes profits to its members.
  • Supplies included tuition, reference books and net books.
  • The fees paid by students are paid as single fees covering all items.
  • Two thirds of the fees were treated as standard rated, one third was taken as zero-rated relating to the books.
  • HMRC assessed the company for VAT on the basis they were providing a single supply of standard rated education.
  • The College appealed to tribunal on the following bases:
    • The supplies were separate supplies, so the books could be zero-rated.
    • If it is a single supply, it is a single supply of exempt education provided by an eligible body.
    • The UK had failed in domestic law to give effect to obligations to provide free education. These obligations prevented the UK from charging VAT.

The FTT dismissed the appeal:

  • As to whether it was a Single or multiple supply:
    • A single fee was charged.
    • There was no opportunity for a student to receive only one part of the supply and not another.
    • The college has not discharged its burden of proof as to whether there is a separate supply. No supporting evidence was provided.
    • Based on the facts, it appears as though the supply from an economic point of view is that of a single supply of education to students.
  • As to whether it was an eligible body providing exempt supplies of Education:
    • The College is not an eligible body under the exemption. It could have been designated as such by the Secretary of State, but it had not been so designated.
    • It may provide education to the same economic level as a University but that does not make it a University.
    • University should take its normal domestic meaning and the College is not a University.
  • Failure to implement international obligations:
    • The obligation to provide free education only extends to elementary and fundamental education and this right exists under UK law.
    • The law referred to is not directly enforceable in UK courts.

The supply was found to be a single supply of standard rated education.


Education & VAT

Single or multiple supply?

External link: Essex International College Limited v HMRC [2018] TC06343



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