What the Glasgow Restaurant VAT Fraud Case Teaches About Tax Compliance

In a recent case in Glasgow, two restaurant owners were found guilty of carrying out nearly a £700,000 VAT fraud scheme. This shocking case highlights the importance of maintaining proper financial records and adhering to VAT regulations.

The Glasgow Restaurant VAT Fraud Case

Two Glasgow restaurateurs were jailed after pleading guilty to large-scale VAT fraud. Antonio Carbajosa (41) and Kevin Campbell (44), involved in the Glasgow Restaurant VAT Fraud Case, ran several Glasgow venues — including Cranside Kitchen, Pickled Ginger, and Halloumi. They admitted fraudulently evading VAT for £682,882 between November 2011 and October 2016.

Their accountant, Khalid Javid (67), also pleaded guilty to submitting false VAT returns on their behalf. 

PersonRoleChargeOutcome
Antonio Carbajosa (41)RestaurateurFraudulent evasion of £682,882 VAT3 years in prison
Kevin Campbell (44)RestaurateurFraudulent evasion of £682,882 VAT3 years in prison
Khalid Javid (67)AccountantFalse statements in VAT returns (2 companies)Pleaded guilty; sentencing pending

How Was the £700k VAT Fraud Scheme Exposed

Both owners suppressed their true sales figures and under-declared their takings. This meant their businesses kept cash that should have gone to HMRC as VAT.

HMRC investigators spotted unexplained discrepancies in the VAT returns. An inquiry called Operation Keyholder followed, with forensic accountants examining accounts from 2012 to 2016. The probe confirmed a total VAT shortfall of £682,882.

Three of their companies were never registered for VAT at all — despite having annual turnovers well above the registration threshold.

The two restaurateurs admitted they and their accountant “acted together in a co-ordinated way” to cheat the VAT system. By hiding sales, the businesses appeared smaller. As the prosecutor noted, the companies could pay bills and draw higher wages because they were pocketing VAT that should have gone to HMRC.

Recent VAT Cases in UK:

How VAT for Restaurants Work

  • Food and drink consumed on the premises is always standard-rated at 20% VAT
  • Service charges and paid tips on top of meals are also subject to VAT
  • Hot takeaway food is usually standard-rated.
  • Cold takeaways and most plain foods are zero-rated or exempt
  • The VAT registration threshold (since April 2024) is £90,000 of taxable turnover

Any business expecting to exceed that in a 12-month period must register and start charging VAT. Businesses must also:

  • Issue proper VAT invoices
  • Keep till receipts and bank statements
  • Pay all VAT collected to HMRC
  • Retain all records for at least 6 years

Consequences of VAT Fraud

Under Section 72 of the Value Added Tax Act 1994, fraudulently evading VAT can lead to:

  • Up to 7 years in prison
  • Unlimited fines
  • Confiscation (POCA) orders to seize illicit gains
  • Criminal records and business bans
  • Reputational damage

Penalties are not limited to business owners. Corporate officers and accountants can also be prosecuted — as this case shows with Mr Javid.

How HMRC Catches VAT Fraud

HMRC uses automated data-matching and analytics to flag anomalies. In this case, HMRC noticed discrepancies in the VAT returns of two of the businesses, which triggered Operation Keyholder.

Common red flags include:

  • Missing till records
  • Undeclared cash sales
  • Invoices that don’t add up

HMRC cross-checks VAT returns against bank deposits, industry benchmarks, and supplier statements.

How We Help Restaurants Manage VAT and Stay Compliant

At Apex Accountants we help businesses navigate VAT rules and handle HMRC enquiries. Our services include:

  • VAT compliance reviews: We review your sales and records to ensure returns are correct and complete
  • VAT registration & planning: We advise on when and how to register, and on available VAT schemes for hospitality businesses
  • Support during HMRC investigations: Our experts guide you through meetings, help prepare responses, and liaise on your behalf
  • Forensic accounting & recovery planning: In serious cases, we reconstruct finances to clarify tax liabilities and protect your interests

Proper guidance can significantly impact the outcome of an investigation, ensuring a smooth process rather than a costly one.

FAQs About VAT For Restaurants

Is all restaurant food subject to VAT? 

Generally yes. Food eaten on-site is standard-rated at 20%. Some cold takeaway food may be zero-rated, but on-premises meals and drinks are a clear-cut VAT case.

What if I forget to register for VAT? 

HMRC can backdate the VAT liability. You may owe unpaid VAT, penalties of up to 100% of the amount owed, and interest. Voluntary early disclosure usually reduces penalties; hiding it can lead to criminal investigation.

Can I get in trouble for honest mistakes? 

HMRC understands errors happen. Genuine mistakes may attract lower penalties. But deliberate under-reporting or falsifying returns is treated as fraud. Even reckless inaccuracies carry serious consequences.

Do I have to repay VAT after conviction? 

HMRC usually tries to recover unpaid VAT through court orders. Businesses should assume they will be held responsible for all unpaid tax.

How can I avoid VAT penalties?

  • Register for VAT when required
  • Charge the correct VAT rates on each sale
  • Keep all invoices, receipts and till rolls
  • File accurate VAT returns and pay on time
  • Get professional advice quickly if HMRC contacts you

What can restaurant owners learn from the Glasgow restaurant VAT fraud case?

The case shows that HMRC treats deliberately suppressed sales and false VAT records as serious tax fraud, not ordinary bookkeeping errors. Restaurant owners should reconcile till records, card receipts, cash takings and bankings; declare all taxable sales, including cash sales; retain supporting records; and obtain professional advice promptly if HMRC opens a VAT compliance check. 

What are the penalties for VAT fraud in the UK?

Deliberate VAT inaccuracies can result in a civil penalty of up to 70% of the potential lost revenue. Where the inaccuracy was deliberate and concealed, the penalty can be up to 100%, depending on the circumstances and the quality of the disclosure. HMRC may also assess the unpaid VAT and charge interest. In serious cases, HMRC can begin a criminal investigation, which may lead to prosecution, fines and imprisonment. 

How should a restaurant prepare for a VAT compliance check?

Before a VAT compliance check, restaurant owners should organise till and point-of-sale reports, booking records, card-payment reports, cash records, bank statements, purchase invoices and VAT returns. Sales records should be reconciled regularly so that cash and card takings are fully accounted for. Businesses should retain the records supporting VAT returns and input-tax claims, file VAT returns accurately and on time, and discuss any payment difficulty with HMRC promptly. The business should also ask its accountant to review the records and identify any errors before responding to HMRC.

What You Need to Know About VAT Exemption for Cultural Services

For UK-based arts and culture organisations, the rules on VAT exemption for cultural services are very important. At Apex Accountants, we help guide cultural organisations so they comply with the law while benefiting where possible. Organisations that need a broader overview of registration, VAT rates and general compliance can also read our guide to everything you need to know about VAT.

What the VAT Exemption For Cultural Services Cover

The VAT exemption applies to the right of admission charges for certain cultural activities. These include entry to museums, galleries, art exhibitions or zoos, and live theatrical, musical or choreographic performances of a cultural nature. However, the exemption applies only if specific conditions are satisfied.

Who Can Use It

Two main types of supplier may qualify:

  • Public bodies, such as local authorities or listed non-departmental public bodies.
  • Eligible bodies, that is, non-profit-making cultural organisations (other than public bodies), which meet defined criteria:
    • Must be non-profit-making.
    • They must apply any profits made from the relevant admission charges to the continuance or improvement of the cultural facilities or activities.
    • They must be managed and administered on a mostly voluntary basis by persons who do not have direct or indirect financial interests in the organisation.

If your organisation is for-profit, or you distribute profits to shareholders, you will not qualify as an eligible body.

What Counts as a Qualifying Supply

The eligibility for the exemption regarding cultural services specifically pertains to admission charges for attending qualifying cultural activities. It is not a blanket exemption from everything your organisation does. Qualifying supplies include admission to a museum, gallery, art exhibition or zoo, or theatrical/musical/choreographic performance of a cultural nature.

Services or goods that are closely related and incidental to that admission may also qualify. But separate commercial activities – for example, venue hire, retail sales, catering, and sponsorship packages – do not normally qualify for the exemption and will be taxable (standard rate). Clear separation in pricing and accounting is vital. 

Common Pitfalls We See

  • Assuming that you are a charity or for public benefit, all your income is VAT exempt. That is not correct. Only the qualifying admission charges may be exempt.
  • Lump-pricing admission plus add-on services (retail, catering) and treating the full price as exempt. This can invalidate the exemption and make the whole supply standard-rated.
  • Relying on eligible-body status without checking the governing documents, management structure and how profits are applied.
  • Treating livestreaming of a performance as an admission to a cultural performance without checking the facts: for example, a tribunal held that a live screening may not meet the “performance of a cultural nature” test and so may not qualify for exemption. 

Case Study: VAT Exemption for Live Screenings – Derby Quad Tribunal Decision

An insightful example of how the UK’s cultural VAT exemption is applied in practice comes from the First-Tier Tax Tribunal (November 2023) involving Derby Quad, a not-for-profit cultural hub in Derby.

Background

Derby Quad operates cinema and event spaces and holds licences to screen plays performed live in theatres. These were “near-simultaneous” satellite transmissions, with audiences watching as the performances happened elsewhere. The organisation believed its ticket sales should qualify for the cultural exemption because they offered admission to a “theatrical performance of a cultural nature”.

Tribunal Decision

The Tribunal ruled that admission to live screenings does not qualify for the cultural VAT exemption. It decided that the screenings were not theatrical performances within the natural and ordinary meaning of that term. 

The key difference was the absence of performer–audience interaction: performers could not respond to the audience, nor did the audience influence the performance. Because this live feedback loop is an essential element of theatre, the Tribunal concluded that Derby Quad’s sales were standard-rated for VAT.

Implications for Cultural Bodies

This case is relevant for arts organisations that livestream or rebroadcast performances. Many had treated income from livestreamed or near-simultaneous events as VAT-exempt during the pandemic. The ruling suggests that such supplies are likely taxable unless the audience and performers share the same physical space.

Key Takeaway

Arts and cultural organisations should review their treatment of livestreamed and broadcast events. Those that declared such income as exempt within the past four years should reassess their VAT position. 

Apex Accountants advises reviewing your contracts, ticketing arrangements, and audience interaction model to confirm the correct VAT treatment and avoid retrospective liabilities.

Practical Steps for Arts Organisations

  1. Confirm your status – check if you are a public body or qualify as an eligible body. Review your constitution, articles, profit-distribution rules, and governance.
  2. Map your income streams – separate admission income from retail, commercial hire, food & drink, and sponsorship.
  3. Structure ticketing and bundles – ensure admission is clearly priced separately if you bundle it with other items.
  4. Maintain proper records – board minutes, pricing policies, ticket terms, and accounting segregation. HMRC expects evidence. If your organisation is VAT registered, it is also important to understand the wider requirements around VAT returns in the UK, including accurate reporting and record-keeping.
  5. Consider input tax recovery – if you make exempt supplies, you will likely fall under partial exemption rules and may not be able to reclaim VAT on all your costs.

Why Organisations Might Choose Taxable Instead

Interestingly, in some cases, it may be preferable for an organisation to make its supply taxable rather than exempt. When a supply is exempt, input tax on associated costs cannot be reclaimed unless you fall under de minimis rules. Choosing taxable supplies could be advantageous if admissions account for the majority of your revenue and your backend expenses are high.

How Apex Accountants Can Help

At Apex Accountants, we specialise in helping arts, cultural, and creative organisations manage VAT compliance with confidence. Our team understands the fine line between exempt and taxable cultural income — from ticketed events and exhibitions to livestreaming and venue hire.

  • Eligibility reviews: we assess whether your organisation meets the HMRC “eligible body” criteria for exemption.
  • Income classification – Our experts separate exempt admissions from taxable commercial activities such as cafés, retail, and sponsorships.
  • Ticketing structure advice – We guide you on pricing, bundling, and contracts to maintain exemption where applicable.
  • Partial exemption calculations – The team helps you manage input tax recovery when both exempt and taxable supplies are made.
  • Livestreaming and digital event reviews – We advise how recent tribunal rulings, like Derby Quad (2023), affect your VAT position.
  • Documentation and audit support – Our VAT experts prepare the evidence HMRC expects, from governance details to pricing policies.

Our goal is to help cultural organisations apply the correct VAT treatments, avoid costly penalties, and maintain accurate financial reporting.

Conclusion

For arts and culture organisations in the UK wishing to apply the cultural services VAT exemption, the key is to check: 

  • you qualify as an eligible body (or public body)
  • you supply the right of admission to a qualifying cultural activity, and 
  • that you separate out any taxable commercial operations. 

At Apex Accountants we help you review your structure, ticketing model and VAT position so you can apply the exemption confidently and handle the non-exempt elements properly. If you would like help assessing your organisation’s risk or VAT exemption eligibility for cultural services, contact Apex Accountants for tailored support.

Frequently Asked Questions

What does the VAT exemption for cultural services cover?

It can cover admission charges by eligible bodies to public exhibitions, theatrical, musical and choreographic performances and similar cultural events. The supply must meet the qualifying conditions set out in the cultural services rules, and not every arts event qualifies.

Who can use the cultural services exemption?

Public bodies and non-profit organisations that are managed and administered on a voluntary basis and meet the qualifying conditions. Commercial operators cannot use the exemption even when the event itself is cultural in nature.

Why might an arts organisation choose taxable over exempt?

Exemption blocks recovery of input VAT on the related costs, so an organisation with significant recoverable costs may be better off charging 20% VAT and reclaiming its inputs. The right choice depends on the cost base and the audience’s ability to bear VAT.

VAT Rules for Education Consultancies Made Simple for UK and International Student Support Providers

Understanding VAT rules for education consultancies is essential for any organisation that supports students with admissions, training, visa processing, or academic placement. 

Education consultants work across the UK and international markets, so they often deal with different VAT rates, exemptions, and cross-border supply rules. These variations impact the invoicing of services, the application of VAT, and the necessity of charging UK VAT.

Because the rules differ for teaching, consultancy, digital learning and overseas student recruitment, it is important to classify each service correctly. Mistakes can lead to incorrect billing, lost VAT recovery or compliance issues with HMRC.

At Apex Accountants, we help education consultancies apply the right VAT treatment, manage cross-border supplies and stay compliant when working with both UK and overseas students.

VAT Basics for Education Consultants

VAT applies differently depending on what you supply. Standard-rated services attract VAT at 20%, while qualifying education and vocational training may fall within the VAT exemption. From 1 January 2025, education, vocational training and boarding supplied for a fee by private schools became standard-rated at 20%. Universities, local authorities and certain further education or qualifying non-profit bodies can continue to exempt eligible education services.

When Education is VAT-Exempt

Under Group 6 of Schedule 9 of the VAT Act 1994, education supplied by an eligible body is exempt from VAT. Eligible bodies include:

  • Public sector schools
  • Universities and further education colleges
  • Not-for-profit institutions
  • Self-employed teachers providing private tuition

English as a Foreign Language (EFL) tuition is also exempt when provided by a commercial provider. However, other commercial training is usually standard-rated.

For education consultancies, this means:

  • Private tuition delivered by a self-employed tutor may be exempt
  • Admission advice, visa support and recruitment services are not exempt
  • Most consultancy work must be billed with VAT at 20%

Standard-Rated Services in Education Consultancy

Most consultancy services fall outside the VAT exemption. These include:

  • Admissions guidance
  • Visa and compliance support
  • Student recruitment
  • Agency-style consultancy
  • Advisory and coaching services

For UK-based clients, these services are standard-rated at 20%. Rechargeable expenses, such as travel, also attract VAT.

As explained by the University of Bath, for overseas clients, the VAT treatment depends on whether the customer is a business (B2B) or a consumer (B2C).

  • B2C: VAT is charged where the consultancy is established → UK VAT applies.
  • B2B: VAT is charged where the customer belongs → no UK VAT

This rule is central to VAT planning for education consultancies working with overseas institutions.

Place-of-Supply VAT Rules for Education Consultancies

HMRC applies different place-of-supply rules depending on how the service is delivered.

Classroom or in-person teaching

If the teacher and student are in the same place, the supply is taxed where it is performed.

Online live teaching

Live online training is treated under the general rule:

  • B2B: VAT applies where the business customer belongs
  • B2C: VAT applies where the supplier belongs (UK VAT charged)

Digital courses and pre-recorded content

Pre-recorded online courses count as digital services.

  • B2B: VAT applies where the customer is located
  • B2C: VAT applies where the customer lives

Suppliers who sell digital services to EU consumers may need OSS registration.

Events and conferences

Admission fees are taxed where the event physically takes place. Running an event overseas may require VAT registration in that country.

Reverse Charge VAT for Overseas Agents

Many education consultancies pay overseas recruiters to source students. These services fall under Reverse charge, because the supplier is outside the UK.

When a UK education consultancy buys services from an overseas agent:

  • The supply is treated as made in the UK
  • The consultancy must apply reverse charge VAT
  • VAT is declared and recovered through the VAT return (subject to partial exemption)

A notable tribunal case (University of Newcastle upon Tyne v HMRC) confirmed that overseas recruitment fees are a single B2B supply to the UK institution. VAT must be accounted for on the full value of the service.

Supplying Services to Overseas Students

The VAT treatment depends on whether the client is an individual or a business.

Advisory services to individuals (B2C)

UK VAT is always charged, even if the student lives overseas.

Services supplied to overseas institutions (B2B)

No UK VAT is charged, because the customer belongs outside the UK.

Digital services to overseas consumers

VAT is charged in the country where the customer resides. If the customer consumes the service outside the UK, UK VAT does not apply.

Training delivered abroad

If the consultancy delivers face-to-face training overseas, UK VAT is not charged. The consultancy may need to register in the host country.

Practical VAT Considerations for Education Consultancies

  1. Check whether any service is exempt: Only education supplied by eligible bodies or private tuition by self-employed teachers qualifies.
  2. Identify whether your customer is B2B or B2C: Ask for VAT registration evidence for business customers.
  3. Apply the reverse charge to overseas purchases: Overseas consultancy fees, agent commissions, and digital services often require reverse charge accounting.
  4. Distinguish between live and digital services: Digital service rules can require OSS registration in the EU.
  5. Consider the impact of private school VAT changes: Private school partners now charge VAT at 20%, which may affect student budgets.
  6. Review partial exemption status: If you supply both taxable and exempt services, you may need a partial exemption method to calculate recoverable VAT.

Accurate records are essential when dealing with taxable, exempt and cross-border supplies. Our outsourced bookkeeping support can help education consultancies maintain organised transaction records, VAT documentation and financial information for ongoing compliance.

How Apex Accountants Supports Education Consultancies with VAT Exemptions

At Apex Accountants, we help education consultancies navigate the complexities of VAT regulations, ensuring accurate billing and compliance. Our expert team assists with VAT exemptions for education providers, helping you understand when services are exempt and when VAT applies. Whether you’re providing tuition, student recruitment, or consultancy services, we offer tailored support to ensure your business stays compliant with UK and international VAT rules. We also guide you through place-of-supply rules and help with cross-border VAT issues, so you can focus on delivering quality services while we manage your VAT obligations. Reach out to Apex Accountants for expert VAT advice and assistance with VAT exemptions for education providers.

Conclusion

VAT treatment in the education consultancy sector relies on the type of service you provide, where it is delivered and who your client is. Teaching supplied by eligible bodies may be exempt, while most consulting, advisory, and recruitment services are standardised at 20%. Cross-border work adds another layer of complexity, particularly when dealing with digital learning, overseas institutions and international student recruitment.

Education consultancies operating through limited companies should also consider VAT alongside their wider company tax position. Our corporation tax services help businesses manage company tax compliance, review available reliefs and plan upcoming liabilities alongside their wider financial obligations. 

Understanding place-of-supply rules, digital service rules, and the Reverse charge VAT for overseas agents is essential for accurate billing and full VAT compliance. A single mistake can affect your VAT recovery status, increase costs for students or create issues with HMRC. Clear classification and proper VAT planning help education consultancies protect their margins and operate with confidence at home and overseas.

At Apex Accountants, we support education consultancies with VAT analysis, invoice accuracy, international supply rules and compliance reviews. Contact Apex Accountants today to get expert guidance tailored to your services and your student markets.

How to Handle VAT for Online Tutoring Companies: What’s Changing in 2026?

VAT for online tutoring companies is becoming increasingly complex, especially with HMRC’s changes taking full effect in 2026. Stricter rules already began in 2025, and the upcoming year will see broader enforcement, particularly for businesses delivering digital courses or using subcontracted tutors.

HMRC now limits VAT exemption for private tuitions to very specific cases. Most tutoring businesses that operate as companies, use subcontractors, or deliver digital content fall outside the exemption scope. This means many online tutoring providers must apply standard-rated VAT at 20% and meet new digital reporting obligations.

If your company offers online lessons, recorded content, or multi-tutor services, these rules affect how you price, invoice, and report VAT. Failing to comply could trigger penalties, backdated assessments, or reputational damage.

At Apex Accountants, we support online tutoring businesses with VAT classification, pricing structure, MTD setup, and HMRC registration—helping you stay compliant while focusing on teaching.

Essential VAT Points for Online Tutoring Businesses

Online tutoring companies must deal with specific VAT rules that affect how their services are taxed. The points below outline the most important areas to review and act on before 2026.

1. Determine if your tuition qualifies for VAT exemption

The VAT exemption for private tuitions only applies in limited situations. According to HMRC guidance:

  • The tutor must supply services on their own account (i.e., not through a company), and the subject must be one normally taught in schools or universities.
  • If you operate via a company or employ tutors, the exemption usually does not apply, and the services become standard-rated VAT at 20%.
  • For “digital” supplies (recorded video courses, subscriptions), HMRC treats them as taxable irrespective of whether the content mirrors school subjects.

Thus, if your online tutoring company delivers structured courses, subscribes tutors under contract, or supplies recorded material, you must treat fees as standard-rated.

2. Understand the impact of recent policy changes

A significant change occurred for private schools from 1 January 2025: the VAT exemption for education and boarding provided by private schools or “connected persons” ended.
Although this change concerns private schools, it signals HMRC’s broad intent to tax educational services more fully. For online tutoring companies this means:

  • Increased HMRC scrutiny of the exemption criteria
  • A need to reassess supply models and contract arrangements
  • Awareness that recorded/digital courses are treated as VAT-taxable services

These VAT changes for online tutoring reflect a broader shift towards stricter digital compliance.

3. Registering for VAT and digital services rules

The UK VAT registration threshold remains £90,000 in any 12-month rolling period. If your business exceeds this, you must register and begin charging VAT.

For digital services (e.g. recorded courses, automated lessons, live webinars), if delivered to UK-based consumers, VAT applies at 20%.

If you sell to customers outside the UK, your services may fall outside UK VAT—but you must assess the recipient’s local VAT or GST position. These cross-border VAT changes for online tutoring require careful planning and categorisation of services.

4. Practical compliance actions for 2026

To maintain compliance and avoid penalties, online tutoring companies should:

  • Monitor rolling 12-month taxable turnover against the £90,000 threshold
  • Separate income streams: exempt tutoring by sole practitioners versus standard-rated company tuition
  • Identify how you deliver: live 1-to-1 lessons may qualify for exemption if delivered correctly; recorded courses typically do not
  • Align pricing strategies: include VAT clearly in your pricing and invoices
  • Keep digital accounting records and submit VAT returns through HMRC-compatible software under Making Tax Digital
  • Review contracts with tutors and subcontractors. If tutors are employees or you invoice through a company, exemption criteria likely fail

5. Why early planning matters

With HMRC tightening compliance and digital supplies under closer examination, early preparation offers benefits:

  • Avoid surprise VAT liabilities or retrospective assessments
  • Preserve competitive pricing without sudden VAT cost shifts
  • Ensure accurate segmentation of services in financial records

6. HMRC’s September 2026 education VAT update

On 2 September 2026, HMRC published Revenue and Customs Brief 9 (2026), updating its position on the VAT treatment of education and closely related services supplied by alternative providers of higher and further education. The update follows the Court of Appeal’s decision in St Patrick’s International College and Others Ltd v HMRC (2026 EWCA Civ 852).

Although this development is important for alternative providers of higher and further education, it does not introduce a new VAT regime for all online tutoring businesses. Providers of ordinary school-subject tuition, private one-to-one lessons, recorded courses or general online tutoring must continue to assess their services under the relevant private-tuition, education and digital-services rules.

For online education businesses, the update highlights the importance of reviewing:

  • Whether the business provides higher or further education
  • Whether the business qualifies as an eligible body
  • Whether its services include education or closely related services
  • Whether any existing reliance on education exemption remains appropriate
  • Whether different services should be treated separately for VAT purposes

Businesses that fall within the scope of HMRC’s updated position may need to reassess their VAT treatment, contracts, pricing and previous VAT returns. However, the brief should not be interpreted as evidence that all online tutoring, recorded courses or digital education services are automatically subject to VAT.

At Apex Accountants we work with online tutoring firms to classify tuition correctly, structure supply contracts, and maintain compliance with evolving HMRC rules. Our approach gives clarity, reduces risk, and supports growth while meeting obligations.

By tackling these five specific areas now, your online tutoring company will be well placed for the VAT changes ahead in 2026.

How Apex Accountants Supports VAT for Online Tutoring Companies

At Apex Accountants, we specialise in helping education and digital service providers meet complex VAT obligations with confidence. Our team understands the fine line between exempt and taxable tuition, and we work closely with online tutoring companies to structure their services correctly.

We offer:

  • Tailored VAT guidance based on your course types, delivery method, and business model
  • Expert support on HMRC classifications for private tuition versus digital services
  • Full VAT registration and compliance assistance, including Making Tax Digital setup
  • Pricing strategy advice to help you remain competitive while meeting VAT rules
  • Contract reviews to help you clarify whether your tutors fall inside or outside exemption criteria

Whether you’re running one-to-one live lessons or offering scalable digital courses, we provide clear, practical support to help your business grow compliantly.

Contact us today for expert guidance and support tailored to your needs.

Understanding the VAT Treatment of Vocational Training Providers

Understanding the VAT treatment of vocational training is essential for organisations delivering professional or skill-based education in the UK. Recent legislative changes mean that more training activities now fall within the scope of VAT, especially where services are delivered by private schools or commercial providers. These updates affect pricing, compliance, record-keeping and how training businesses manage input tax recovery.

Private Schools and VAT Rules for Vocational Training Providers

Since 1 January 2025, education, vocational training and boarding supplied for a charge by private schools or connected persons in the UK have generally been subject to VAT at the standard rate of 20%. 

Private schools and connected persons must register for VAT where their taxable turnover exceeds £90,000 in the previous 12 months, or where they expect it to exceed £90,000 in the next 30 days.

The 20% VAT treatment generally covers:

  • Tuition and education fees
  • Vocational training supplied by a private school
  • Boarding or accommodation supplied by the school

Qualifying nursery education remains exempt, and most other qualifying goods and services supplied directly for pupils’ use may also remain exempt.

The rules prevent schools from avoiding VAT simply by bringing payments forward. Payments made on or after 29 July 2024 for education or boarding relating to terms beginning on or after 1 January 2025 are generally subject to VAT.

The VAT position for other vocational, further and higher education providers must be considered separately. Following the Court of Appeal decision in St Patrick’s International College and Others Ltd v HMRC, HMRC issued Revenue and Customs Brief 9 (2026), confirming that some supplies by alternative higher and further education providers may qualify for exemption.

Is Vocational Training VAT-exempt?

Vocational training can be VAT-exempt when it is supplied by an eligible body that meets HMRC’s VAT rules for education and vocational training. 

Eligible bodies may include:

  • Universities
  • Further education colleges
  • Local authorities
  • Certain public bodies
  • Qualifying non-profit organisations

Private tuition may also qualify for VAT exemption when it is supplied independently by an individual teacher in a subject ordinarily taught in a school or university. However, the exemption does not automatically apply to all private training providers.

Vocational training supplied by an eligible body can remain exempt where that body specifically subsidises part of the cost.

Private schools are subject to separate rules. Since 1 January 2025, education and vocational training supplied for a charge by private schools or connected persons have generally been subject to VAT at the standard rate of 20%.

Carve-Outs for Independent Training Providers

The private-school VAT rules specifically exclude qualifying Independent Training Providers (ITPs) and Independent Learning Providers (ILPs). These organisations commonly provide vocational education, apprenticeships and skills programmes under contracts funded by relevant government authorities.

However, the exclusion applies only where the provider meets the statutory definition and relevant funding conditions. It does not mean that all training supplied by ITPs or ILPs is automatically VAT-exempt.

Further education colleges also generally remain outside the private-school VAT regime. The rules mainly apply to institutions that:

  • Provide full-time education mainly to students aged 16 to 19
  • Fund that education mainly through fees
  • Do not qualify as an ITP or ILP under the relevant provisions

Certain other supplies are also excluded from the private-school VAT rules, including:

  • Nursery classes that meet the statutory conditions
  • Qualifying Teaching English as a Foreign Language (TEFL) courses supplied by private schools or connected persons

English-language teaching should therefore not be described as universally excluded. The carve-out applies specifically to qualifying TEFL courses.

The underlying VAT treatment must still be considered separately. Depending on the provider, funding arrangements and nature of the training, a supply may be VAT-exempt, outside the scope of VAT or standard-rated.

Government-Funded Training Remains Exempt

Qualifying vocational training funded wholly or partly by government programmes can remain VAT-exempt, but only to the extent of the qualifying funding. This may include training funded through:

  • The Department for Education.
  • Apprenticeship service or levy-funded programmes.
  • Local authority funding.
  • Approved schemes financed from European Social Fund funding.

Apprenticeship training or assessment paid for through government funding, including the apprenticeship levy, is exempt from VAT.

VAT Responsibilities for Providers Who Fall Within Scope

Training providers that must charge VAT need to:

  • Register for VAT once taxable turnover exceeds £90,000.
  • Charge the correct VAT rate on taxable training services, normally 20%.
  • Issue VAT-compliant invoices.
  • Keep digital VAT records under Making Tax Digital.
  • Submit VAT returns using compatible software.
  • Reclaim eligible input VAT on costs linked to taxable supplies, such as training materials and administration expenses.

Input VAT directly linked to exempt activities cannot normally be recovered. Providers making both taxable and exempt supplies may therefore need to carry out partial-exemption calculations and apportion input VAT. Some input VAT may still be recoverable under the de minimis rules.

One further qualification: the £90,000 threshold is based on taxable turnover, not total income. Providers should also consider whether they must register because they expect to exceed the threshold in the following 30 days.

Transitional Rules and Anti-Avoidance Measures

Prepayments made on or after 29 July 2024 for private-school education or boarding relating to terms beginning on or after 1 January 2025 are generally subject to VAT at the standard rate of 20%. The rule is intended to prevent schools and customers from avoiding VAT simply by bringing payment dates forward.

Payments received between 29 July and 30 October 2024 for education provided in a school term beginning on or after 1 January 2025 are treated as supplies taking place on the later of 1 January 2025 or the first day of the relevant term.

Payments made before 29 July 2024 may fall outside these specific transitional provisions, but providers should review the contract, payment date and nature of the supply rather than assume that all such payments are protected. HMRC may challenge arrangements that are artificial or designed to avoid the new VAT charge.

Why VAT Planning Matters

The shift in VAT rules represents a significant financial and administrative change for many training providers. Identifying whether your organisation is exempt, partially exempt or fully taxable is essential. Pricing strategies, contractual terms and VAT recovery calculations all require careful reviews.

Early planning helps avoid unexpected liabilities and protects cash flow.

How Apex Accountants Support the VAT Treatment of Vocational Training Providers

At Apex Accountants, we help training providers understand their VAT obligations and manage a smooth transition into the updated VAT rules for vocational training providers. Our services include:

  • Reviewing eligibility for VAT exemption
  • Advising on VAT registration and digital record-keeping
  • Preparing partial exemption calculations
  • Supporting providers in government-funded schemes
  • Reviewing pricing, contracts and payment structures
  • Implementing MTD-compliant VAT systems

We work closely with training businesses to minimise VAT exposure and strengthen compliance so they can focus on delivering high-quality learning.

Conclusion

The VAT rules have shifted in recent years, raising concerns such as, is vocational training VAT-exempt? Many exemptions still apply, particularly for eligible bodies and government-funded providers. Understanding whether your organisation falls within your scope is essential. With the right guidance, you can manage VAT efficiently, protect your margins and stay compliant.

For tailored support with VAT and wider tax matters, contact Apex Accountants today.

Can You Reclaim VAT on Transaction Fees in the UK

Most businesses ask this as a yes-or-no question, but UK VAT does not work that neatly. Whether a business can reclaim VAT on transaction fees depends on who received the service, what the transaction was for, and whether the cost links to taxable business activity rather than a passive investment or an exempt share sale.

How VAT on Deal Fees is Applied in Various Situations

Deal situationUsual VAT outcome
A trading company issues new shares to raise funds for its taxable businessOften recoverable under the normal rules, because a new share issue is not a VAT supply in itself. If the issue supports economic activity, the related VAT can be input tax, subject to partial exemption if relevant. 
A passive holding company buys shares to earn dividends or sell later for gainUsually not recoverable. Pure shareholding for dividends or capital growth is treated as investment activity, not taxable business activity. 
A holding company buys a subsidiary and supplies genuine management services for real considerationOften recoverable, but only if the holding company is the recipient of the adviser services, carries on economic activity, and makes taxable supplies. Partial exemption can still reduce the claim. 
An acquisition is a direct extension of an existing taxable tradeOften recoverable. Such as buying a competitor, a key supplier, a key customer, or a property-owning subsidiary from which the buyer intends to trade. 
A business sells existing sharesUsually restricted or blocked, because the sale of existing shares is normally an exempt supply. If the share sale is only incidental to the wider business, there are special partial exemption rules rather than an automatic full block. 
The target company incurs vendor due diligence costsRecovery can be possible for the target if the target is the actual recipient of the services and they were received for its own business. 
A deal aborts after fees have been incurredRecovery can still be possible if there is genuine, objective evidence of an intention to make taxable supplies. Failed projects do not automatically destroy recovery. 

How VAT Applies to Common Payment Processing Fees

VAT treatment can vary between payment providers and by the type of service supplied. While many financial services are VAT-exempt, technical or administrative payment-processing services do not automatically qualify for that exemption.

Businesses should therefore check the provider’s invoice, the contracting entity and the nature of each charge before treating transaction fees as recoverable input VAT.

Stripe

Stripe fees are not automatically VAT-exempt. Card-processing services can be subject to standard-rated VAT where the service is treated as taxable payment processing.

The exact VAT treatment can depend on which Stripe entity provides the service, whether the supply is made from the UK or cross-border, and the particular service being charged for. Different treatment may apply to services such as terminal hardware, platform fees, payouts or other additional features.

Where the supply is cross-border, businesses may also need to consider whether the reverse charge applies.

PayPal

Some core PayPal payment services may qualify for the VAT exemption that applies to certain financial services, particularly where the service involves the transfer or movement of funds.

However, this does not mean every PayPal charge is VAT-exempt. Additional merchant services, administrative charges and other ancillary services can have different VAT treatment.

Businesses should review the individual charge and supporting invoice rather than assuming all PayPal fees receive the same VAT treatment.

GoCardless

GoCardless generally charges standard-rated VAT on UK transaction fees. Since April 2020, its UK transaction fees have been treated as taxable supplies rather than VAT-exempt financial services.

Where VAT is correctly charged, a VAT-registered business may be able to reclaim it subject to the normal input tax recovery rules and the use of the service for taxable business activities.

Traditional Banks

Many core banking services are VAT-exempt under the financial services exemption. This commonly includes standard banking and payment services.

However, banks may also provide additional or ancillary services that are taxable. Charges for certain administrative, advisory or other non-financial services may therefore include VAT.

For VAT recovery on bank charges, businesses should check each charge individually to confirm whether VAT has actually been applied and whether it is recoverable under the normal input tax rules, rather than assuming every fee on a bank statement is VAT-exempt.

Why Payment Processing Fees Are Not Always VAT-Exempt

The VAT exemption for financial services does not automatically extend to every service involved in making or receiving a payment.

Following court decisions including Bookit and NEC, HMRC distinguishes between services that actually perform an exempt financial transaction and technical or administrative services that simply facilitate card payments. Card-handling and processing services that only enable a customer to make a payment can therefore be standard-rated at 20%.

The key point is that a transaction fee does not automatically contain reclaimable VAT. Businesses should check whether VAT has actually been charged, identify what service the fee relates to and confirm that the normal input tax recovery conditions are met before including it on a VAT return.

What Decides Whether to Reclaim VAT on Transaction Fees

Three questions usually decide the result. 

  1. Was the fee incurred in taxable business activity?
  2. Is there a direct and immediate link between that cost and taxable supplies? 
  3. Is the business claiming the VAT actually the recipient of the service?

That is why labels like “legal fee”, “corporate finance fee” or “due diligence fee” do not settle the point on their own. The same type of cost can be recoverable in one structure and blocked in another, simply because the underlying activity is different.

Importance of the Invoice Trail

A second point is often missed: the invoice trail matters. Whether the claimant contracted for the service, was invoiced, paid for it, and made use of it, while general VAT record rules also require valid VAT invoices and records that support the claim.

Using professional accounting services can also help ensure adviser invoices, payments and supporting records are captured consistently before the VAT return is prepared.

Partial Recovery for Mixed Activity

If a business has both taxable and exempt activity, it may only recover the taxable portion unless the de minimis rules help. The current de minimis limit is £625 per month on average and no more than half of the total input tax, with an in-period check and a year-end review.

Practical Takeaways

  • Decide early on the recipient entity: Decide before the first engagement letter is signed which entity should receive the service, because attribution is based on actual or intended use when the purchase is received.
  • Give the holding company a real taxable role: If a holding company is meant to recover VAT, give it a real taxable role. Genuine management services for more than nominal consideration are a strong starting point.
  • Expect partial exemption with loans: If the structure also includes interest-bearing loans, expect partial exemption to enter the picture.
  • Don’t ignore the year-end de minimis review: A claim that looks acceptable during the year can be clawed back later if the annual test fails.

Read: Court of Appeal ruling puts VAT on education grants under scrutiny 

How common deal structures are treated

Share acquisitions through a holding company

A holding company does not get recovery just because it owns subsidiaries. If it only holds shares, receives dividends and hopes for a later sale, that is investment activity, and the VAT on acquisition costs is normally not recoverable. 

The position improves where the holding company buys the subsidiary to make taxable management services for consideration. The acquisition costs of such a holding company are part of its general overheads, so the VAT can be deductible only if the holding company receives the adviser services and makes taxable supplies. 

A practical observation here is that vague plans do not help much. If the structure only contemplates charging the subsidiary “at some point later” or only if profits allow, that is weak; official case summaries and guidance both stress the need for genuine, priced services and real consideration. 

Acquisitions that strengthen an existing trade

Not every acquisition needs a separate management charge to support recovery. Share acquisition can sometimes be a direct, continuous and necessary extension of an existing taxable trade, such as buying a competitor, a key supplier, a key customer, or a property-owning subsidiary from which the buyer plans to trade. 

That is a useful point in real deals. If a trading business buys a company to reinforce its own trading operation, the fee can sometimes sit with the buyer’s existing taxable business rather than a standalone investment case. 

Share Sales and VAT

A sale of existing shares is normally an exempt supply. That is why VAT on legal and advisory fees linked directly to a share disposal is usually a problem, and a wider commercial reason for the sale does not automatically fix it.

Immediate Transaction Matters

That last point matters. Selling shares to raise money for wider taxable trading does not by itself turn the disposal fees into recoverable VAT, because the immediate transaction still matters.

Restructuring Context

There is, though, an important nuance. Some disposals in a restructuring context may fall within economic activity where the disposal is a direct, permanent and necessary extension of the taxable business, but this is fact-sensitive and should never be assumed.

Standard Partial Exemption Method

If the business uses the standard partial exemption method and a share sale is merely incidental to the main business, the value of that share sale should be excluded from the standard method calculation. The VAT on the related costs is then dealt with using normal attribution rules rather than by simply including the deal in the denominator and accepting the result.

Special Method and Residual Costs

If the business uses a special method, certain residual costs on incidental share sales must be apportioned by use. Costs such as:

  • Accountants
  • Financial advisers
  • Lawyers
  • Advertising agencies
  • Marketing consultants
  • Listing and registration services
  • Document preparation services

Share Sales Are Not TOGC

One other point saves confusion in practice: a share sale is not a TOGC. Where a limited company changes hands by way of a share transfer, the assets remain owned by the company, so there is no asset transfer to which TOGC rules apply.

Fundraising and VAT

A new share issue is treated differently from a sale of existing shares. The issue of new shares is not a supply for VAT purposes, and related VAT can be recoverable to the extent the issuer’s business generates taxable supplies.

Target-Side Fees

On the seller side, the target company’s own fees can sometimes be overlooked. Vendor due diligence and similar costs incurred by the target may be deductible where:

  • The target is the recipient of the services
  • The services were received for the target’s business

Aborted Deals

Aborted deals are not automatically lost causes either. If there was genuine objective evidence that the business intended to make taxable supplies, preparatory VAT can still be recoverable even where the project fails before those supplies are made.

A Must Read: Everything About VAT Return Deadlines in the UK

Check the Adviser’s VAT Status

Also check whether there is actually any VAT on the adviser bill in the first place.

  • Pure advice, such as advice on capital raising or defending takeovers, is taxable
  • A genuine intermediary service in a securities transaction can itself be exempt if it meets the exemption conditions

How to improve the chances of recovery before the deal closes

The biggest practical point is timing. VAT attribution is based on how the service is used, or intended to be used, when the service is received, so sloppy structuring at the start of the deal is hard to repair later. 

In real transactions, the weak spot is often not the technical rule. It is the evidence pack: the engagement letter is in one company’s name, the invoice is sent to another, and the payment comes from a third. That makes it much harder to show who really bought and used the service. 

Document or stepWhy it matters
Engagement letter in the right entity’s nameHelps show which business contracted for the service and was the recipient. 
VAT invoice in that same entity’s nameA recoverable claim needs a valid VAT invoice and records that support it. 
Payment trailOfficial guidance on recipient status looks at who paid for the service as well as who contracted and who used it. 
Board minutes, deal papers and business planThese can provide objective evidence of intended taxable supplies, especially where the deal never completes or charges begin later. 
Management services agreement with a real charging modelHelps show that services are genuine, for consideration, and more than nominal. 
Actual management invoices after completionStrong evidence that the structure reflected real taxable activity rather than a vague future intention. 
Partial exemption workingsEssential where deal fees support both taxable and exempt activity, including share sales or exempt lending. 
Six-year retention of VAT recordsVAT records generally need to be kept for at least six years. 

A final but important point is VAT grouping. Joining a VAT group does not automatically create recovery, and it does not turn passive investment activity into taxable business activity. 

Where claims usually break down

The most common failure point is assuming that “commercial purpose” is enough. It is not enough to say the deal helped the group overall; what matters is the VAT link between the cost and taxable outputs. 

Other problem areas come up again and again:

  • Passive holding activity dressed up as a business activity. Receiving dividends and holding shares is not enough on its own. 
  • Management services that are never properly priced or invoiced. A loose intention to charge later is weak evidence. 
  • Assuming a later VAT group will rescue old acquisition VAT. It does not do that automatically. 
  • Invoices and contracts sitting with the wrong entity. The claimant still needs to show it received, used and paid for the services. 
  • Forgetting the share-sale rules in partial exemption. Incidental share sales have their own treatment under both standard and special methods. 
  • Ignoring the possibility that the adviser’s own service was exempt. Pure advice is usually taxable, but some intermediary work in securities transactions can be exempt instead. 
  • Missing the annual de minimis re-test. Recovery allowed during the year can still be reversed at year end. 

A smaller but still important trap is “stewardship” or group overhead costs. Some group audit, legal, regulatory, brand defence and bid defence costs may really belong to the group as a whole, even if the holding company receives the invoice for convenience. 

How Apex Accountants Can Help Reclaim VAT on Transaction Fees

At Apex Accountants, we keep this area practical. Our focus is not just on whether VAT looks reclaimable in principle but on whether the contract, invoice trail, management model and partial exemption position actually support the claim.

We help clients with:

  • reviewing legal, due diligence, corporate finance and other transaction fees line by line
  • checking which entity should contract for, receive and pay each adviser
  • building evidence for management charges, intended taxable supplies and aborted deals
  • calculating partial exemption, de minimis and pre-registration claims
  • reviewing VAT grouping points before and after completion
  • preparing clear support packs for internal sign-off and external review

Conclusion

VAT recovery on deal fees is possible, but it is rarely automatic. The strongest claims usually involve one of two positions: the fee sits inside an existing taxable business, or the acquiring company is carrying on real taxable activity and can prove it with proper documents and real charges. 

Claims usually fail for the opposite reasons. The structure is really an investment; the fee links to an exempt share sale, the wrong entity received the service, or the paperwork does not match the story the business wants to tell. 

FAQs on VAT on Deal Fees

Can a holding company reclaim VAT on acquisition fees?

Yes, but not just because it is a holding company. Recovery normally depends on the company being the recipient of the adviser services, carrying on economic activity, and making taxable supplies such as genuine management services for consideration. 

What if the holding company only receives dividends?

That usually points the wrong way. Simply holding shares for dividends or a later capital gain as investment activity, not taxable business activity. 

Do management charges need to be real and priced?

Yes. The services need to be genuine, provided for consideration that is more than nominal, and not left as a vague future idea that may or may not be billed later. 

Does the invoice need to be in the claimant’s name?

In practice, yes, that is the safest position. Whether the claimant contracted for the service, was invoiced, paid for it and used it, and normal VAT rules also require valid VAT invoices and records to support the claim. 

Does joining a VAT group automatically fix the issue?

No. Joining a VAT group does not automatically create recovery and does not turn passive investment activity into taxable business activity. 

Can VAT on share sale fees be recovered?

Usually not in full, because the sale of existing shares is normally an exempt supply. If the share sale is only incidental to the wider business, special partial exemption rules may soften the effect, but that is not the same as an automatic full reclaim. 

Can a partly exempt business still recover all the VAT?

Sometimes. If the exempt input tax is no more than £625 per month on average and no more than half of the total input tax, the de minimis rules can allow full recovery, but the position must still be reviewed at year-end. 

Can the target company recover VAT on vendor due diligence?

It can if the target is the real recipient of the services and the services were received for the purposes of the target’s own business. 

What if the deal aborts?

A failed deal does not automatically kill the claim. Where there was genuine, objective evidence of an intention to make taxable supplies, preparatory VAT can still be recoverable even if the business never reaches the point of making those supplies. 

Can pre-registration VAT on deal fees be reclaimed?

Potentially, yes. For services, normally a six-month lookback before registration, while goods can go back four years, but only where the costs were bought for the taxable business that is now registered.

Do Hairdressers Charge VAT in the UK?

The question, “Do hairdressers charge VAT in the UK?” is one that many salon owners, freelance stylists, and mobile hairdressers often ask. The answer depends not on the type of business but on turnover. Like all other UK businesses, hairdressers must follow HMRC’s VAT (Value Added Tax) rules, which are closely tied to income thresholds. Once a business grows beyond a set level, VAT registration becomes compulsory, and this has direct consequences for pricing, profit margins, and customer perception.

This article provides a detailed explanation of VAT requirements for hairdressers. It covers the registration threshold, rules for different business models, exemptions, the standard VAT rate, and the practical effects on the hairdressing industry. It also highlights how Apex Accountants can help hairdressers manage VAT effectively.

What is the VAT registration threshold for hairdressers?

The VAT registration threshold is the first factor to consider. For 2026/27, the VAT registration threshold remains £90,000 in taxable turnover. This means that if a hairdresser, salon, or barber shop has taxable turnover of more than £90,000 in any rolling 12-month period, they must register for VAT with HMRC. 

It is important to note that this is a rolling 12-month period, not a tax-year test. Businesses should review their taxable turnover regularly. Compulsory VAT registration applies once taxable turnover for the previous 12 months goes over £90,000. A business must normally register within 30 days of the end of the month in which it exceeded the threshold. 

On the other hand, if turnover later drops below £88,000, a hairdresser may apply for deregistration. This flexibility helps businesses that experience seasonal fluctuations or temporary drops in revenue. However, many businesses in the sector deliberately remain under the threshold to avoid the administrative burden and financial implications of VAT.

How the £90,000 rolling VAT threshold works 

A salon taking £7,500 per month would have a taxable turnover of exactly £90,000 after 12 months. That alone does not exceed the VAT registration threshold. However, if its rolling 12-month taxable turnover rises above £90,000, it must register for VAT. For example, if turnover reaches £90,500, the business must normally register within 30 days of the end of the month in which it exceeded the threshold. 

Do all hairdressers have to charge VAT once registered?

The obligation to charge VAT does not depend on the type of business. Whether someone is a self-employed stylist, a salon owner, or a mobile hairdresser, the same rule applies: once the threshold is exceeded, VAT registration is compulsory and VAT must be charged.

  • Independent and self-employed hairdressers must register when their taxable turnover from services and product sales goes above £90,000 in a rolling 12-month period. Below the threshold, VAT registration is not compulsory, although voluntary registration is available.
  • Salon businesses must take a wider view of turnover. Income from services, retail sales, and even chair rental fees from freelancers all count toward the threshold. Once this total passes £90,000, VAT registration is unavoidable.
  • Chair rental arrangements can tip many salons into VAT. HMRC clarified that chair rentals are taxable at the standard rate, meaning this income cannot be excluded.
  • Mobile hairdressers, who often earn below the threshold, usually do not charge VAT. However, if their earnings grow – perhaps by catering to events, building a larger client base, or hiring additional help – VAT may come into play.

Employees working in salons never charge VAT personally. Instead, the salon or company they work for is responsible for VAT registration and collection.

Are there any VAT exemptions for hairdressers?

There are no sector-specific VAT exemptions for hairdressers. In other words, there is no special rule that removes hairdressers from the VAT system. All standard services, such as cutting, colouring, and styling, are taxable at the standard rate.

Businesses whose taxable turnover remains below the £90,000 registration threshold are not normally required to register for VAT. This is a registration threshold rather than a VAT exemption. Hairdressers who are not VAT-registered do not charge VAT on their taxable services and cannot reclaim input VAT on business costs. Some choose to register voluntarily to reclaim VAT on eligible expenses. Once registered, they must account for VAT on their taxable services and sales. 

What VAT rate applies to hairdressing services?

Hairdressing services are subject to the standard VAT rate of 20%. Unlike some sectors, such as hospitality, which temporarily benefited from a reduced VAT rate during COVID-19, hairdressers have always remained at the standard rate.

For example, a £50 haircut advertised before VAT becomes £60 once VAT is added. Many salons therefore prefer to display VAT-inclusive prices to avoid confusing clients. While customers of VAT-registered businesses pay more, customers of smaller, unregistered salons or mobile hairdressers do not pay VAT on top of quoted prices.

Some salons use HMRC’s Flat Rate Scheme. Under the scheme, a hairdressing business still charges the normal VAT rate to customers but calculates the amount it pays to HMRC using a flat-rate percentage. The Flat Rate Scheme percentage for hairdressing and other beauty treatment services is 13%, although businesses classed as limited-cost businesses may have to use the higher 16.5% rate. The scheme can simplify VAT accounting, though it may not suit every business. 

How does VAT affect pricing and profits for hairdressers?

VAT for hairdressers has a significant impact on pricing. Once registered, a hairdresser has two main choices:

  1. Increase prices by around 20% so the VAT is passed directly to customers. This can make services appear less competitive compared to non-registered stylists.
  2. Absorb the VAT cost and keep prices the same, but sacrifice part of the profit margin. This is often unsustainable in the long term.

Because hairdressing is labour-intensive, salons may have fewer VAT-bearing costs to reclaim than some other businesses. Wages do not carry VAT, while chair rental supplied by a VAT-registered salon is generally taxable. The amount of input VAT a salon can reclaim will therefore depend on its particular costs and business arrangements. 

This pressure has led to calls within the industry for a reduced VAT rate, but hairdressing services continue to be subject to the standard VAT rate in 2026/27. 

Conclusion: Do hairdressers charge VAT in the UK?

  • Hairdressers only charge VAT if they are VAT-registered.
  • Registration is compulsory once turnover exceeds £90,000 in any rolling 12 months.
  • VAT applies equally to salons, self-employed stylists, and mobile hairdressers.
  • All services are taxed at the standard 20% rate.
  • No specific VAT exemptions exist for the sector.

Smaller operators below the threshold do not charge VAT, which is why many remain outside the VAT system. Larger salons and growing freelancers, however, must register and adjust their pricing strategies accordingly.

How Apex Accountants can help hairdressers with VAT

For many in the hair and beauty industry, VAT is one of the most difficult financial challenges. At Apex Accountants, we work closely with salon owners, freelance stylists, and mobile hairdressers to make VAT management simpler and less stressful.

Our VAT services for hairdressers include:

  • Monitoring turnover and advising when VAT registration is required.
  • Registering businesses for VAT and handling deregistration when appropriate.
  • Preparing and filing VAT returns with HMRC.
  • Advising on pricing strategies that maintain competitiveness while staying compliant.
  • Exploring schemes such as the Flat Rate Scheme to simplify VAT reporting.
  • Representing clients in communications with HMRC and ensuring all obligations are met.

By partnering with Apex Accountants, hairdressers can focus on delivering great service to clients while we take care of VAT, compliance, and financial strategy.

Book a free consultation with Apex Accountants today and let us help your hairdressing business grow with confidence.

FAQs on VAT for Hairdressers and Beauty Salons in the UK

1. What is the VAT rate for hairdressers in the UK?

Hairdressing services in the UK are taxed at the standard VAT rate of 20%. This applies to all haircuts, styling, colouring, and similar services once a business is VAT-registered.

2. Is there VAT on beauty products in the UK?

Yes. Most beauty products, such as shampoos, conditioners, hair dyes, and cosmetics, are subject to the standard VAT rate of 20%. Only a few items, like certain health-related products, may fall under reduced or zero rates.

3. Do self-employed hairdressers have to pay VAT?

Self-employed hairdressers only need to register for VAT if their taxable turnover exceeds £90,000 in any rolling 12-month period. Below this threshold, they are not required to charge VAT, although voluntary registration is allowed.

4. Do you charge VAT on chair rental in a salon? 

Chair rental is generally a taxable supply. If a VAT-registered salon rents chair space to a self-employed stylist, the salon normally charges VAT on that rental income. Chair-rental income also contributes to the salon’s taxable turnover when determining whether it needs to register for VAT. 

5. Do self-employed hairdressers pay tax to HMRC?

Yes. Self-employed hairdressers must submit a self-assessment tax return each year and pay income tax and national insurance on their profits. VAT is separate and only applies if they cross the registration threshold.

6. Are beauty salons required to be VAT registered?

A beauty salon must register for VAT once its taxable turnover exceeds £90,000 in a rolling 12-month period.  If it remains below the threshold, registration is not required. Some salons choose to register voluntarily to reclaim VAT on expenses.

7. What is the VAT threshold in the UK?

For 2026/27, the VAT registration threshold remains £90,000. Businesses whose taxable turnover goes over this amount in a rolling 12-month period must register with HMRC. The VAT deregistration threshold remains £88,000. 

8. Do hairdressers have to pay VAT on their services?

Yes, once registered. Hairdressers who cross the VAT threshold must add 20% VAT to all their services. Those below the threshold do not charge VAT to customers.

9. Are beauty treatments subject to VAT in the UK?

Yes. All standard beauty treatments, such as facials, manicures, and waxing, are taxed at the 20% VAT rate when the salon or beautician is VAT-registered.

10. Does hairdressing attract GST instead of VAT?

No. The UK does not use GST (Goods and Services Tax). Hairdressing services in the UK are covered under VAT, with the standard rate of 20% applying to all taxable services.

11. Is VAT always 20% for everything in the UK?

No. While many goods and services, including hairdressing and beauty, are taxed at 20%, some items fall under reduced rates (5%) or are zero-rated. For hairdressers, however, services and most products are charged at the standard 20% rate.

UK VAT On Prize Draws Faces Scrutiny As HMRC Clarifies Tax Position

Paid entries to UK online prize draws are subject to VAT at the standard 20% rate when the entry fee buys a place in a draw rather than a free competition route. HMRC’s clarified position means operators must account for output tax on paid entries, while genuine free-entry competitions stay outside VAT. 

The UK government has confirmed that paid entries to online VAT on prize draws offering both a free and paid route will be subject to value added tax (VAT) at the standard rate, challenging the widespread assumption that such draws fall within the betting and gaming exemption. Responding to a House of Commons question tabled on 9 February, Treasury minister Dan Tomlinson stated on 17 February that HM Revenue & Customs (HMRC) “confirm that prize draws offering both paid and free entry routes are not eligible for VAT exemption and paid entries will be subject to VAT at the standard rate of 20%”. The clarification comes as the Department for Culture, Media & Sport (DCMS) prepares to implement a voluntary code of practice for prize draw operators and as the sector attracts increased regulatory and fiscal scrutiny.

Why VAT on online prize draws matters

Prize draws have become a lucrative segment of the UK online promotions market, and VAT on online prize draws is increasingly under scrutiny. Independent research commissioned by DCMS estimated that around 7.4 million adults took part in prize draws and competitions (known collectively as PDCs) in the 12 months to November 2023, spending around £1.3 billion—with a market size range of £700 million to £2.1 billion. The sector is dominated by around 400 operators and is growing rapidly, prompting concerns about consumer protection, gambling harm and tax compliance. The Treasury’s recent statement, coupled with the forthcoming voluntary code, means operators must reassess whether their ticket sales attract VAT and consider potential historic exposures.

HMRC’s Clarified Position in Brief

  • HMRC confirmation: The government has confirmed that prize draws with both paid and free entry routes are not covered by the VAT exemption for betting, gaming, and lotteries; VAT for online prize draw operators will apply at 20% for paid entries.
  • Policy trigger: The clarification followed a parliamentary question about the tax treatment of such draws, asked amid the roll‑out of the voluntary code of practice.
  • Growing market: Research shows 7.4 million participants and annual spending around £1.3 billion, with at least 401 operators, each of whom must understand VAT for online prize draw operators to avoid penalties. 
  • Exemption complexities: VAT legislation exempts facilities for betting or playing games of chance, but the supply of games of skill is standard‑rated. The classification of prize draws sits in this grey area.
  • Voluntary code: Operators signing the code must implement its player‑protection measures within six months and no later than 20 May 2026.
  • Uncertain tax treatment: Larger businesses taking a tax position inconsistent with HMRC’s “known position” must notify HMRC under the uncertain tax treatment regime.

What Has Happened with VAT on Prize Draws

A written question from Maureen Burke, Labour MP for Glasgow North East, asked the Chancellor to clarify the VAT treatment of ticket sales for online prize draws that offer both a paid and a free entry route. In the response on 17 February 2026, Treasury minister Dan Tomlinson confirmed that HMRC regards paid entries as standard‑rated supplies, meaning VAT must be charged at 20 %. The minister’s statement effectively rejects the view that such draws are exempt under Group 4 of Schedule 9 to the Value Added Tax Act 1994, which exempts facilities for betting, gaming and lotteries.

The parliamentary question reflects growing uncertainty in the sector. Many operators have treated their prize draws as VAT‑exempt on the basis that they provide a game of chance similar to a lottery. HMRC’s position draws a distinction between games of chance, which are exempt, and games of skill or commercial competitions, which are standard‑rated. The government’s clarification suggests that a dual‑entry prize draw—where free postal entries coexist with paid online tickets—does not fit neatly within the gambling exemption.

Why Prize Draws Attracted HMRC Scrutiny

Under existing HMRC guidance, supplying facilities for betting or playing games of chance is normally exempt from VAT. A game of chance involves an outcome determined wholly or partly by chance, whereas games of skill, such as certain competitions, are subject to VAT. HMRC’s VAT notice cites “spot the ball” competitions as examples; these were deemed games of chance and thus exempt after a Court of Appeal ruling in 2016. The line between skill and chance, however, is nuanced. In prize draws offering both free and paid entry, HMRC appears to consider the paid ticket sale as a taxable supply rather than a stake in a game of chance.

The value of the exemption may be substantial. Participation in games of equal chance became VAT‑exempt from 29 April 2009, and the exemption covers stakes or takings less any winnings. Operators who have not accounted for VAT on ticket sales may face assessments, penalties and interest. Moreover, under the uncertain tax treatment (UTT) regime, large businesses must notify HMRC when they take a tax position that is uncertain and exceeds a £5 million tax advantage. Treating prize draw entries as exempt despite HMRC’s stated position would therefore trigger a disclosure obligation.

Key details or changes

The voluntary code of good practice for prize draw operators, published by DCMS and updated in February 2026, contains detailed measures on player protection, transparency and accountability. Signatories must fully implement the code within six months of publication and no later than 20 May 2026, sharing best practices and supporting non‑signatories. The code prohibits operators from accepting credit card payments above £250 per month per player, requires age verification and clear complaints processes, and encourages spend limits and self‑exclusion options. While the code does not address VAT directly, it signals heightened regulatory interest in the sector.

The research commissioned by DCMS highlights the scale of the market and its proximity to gambling. An estimated 88 % of prize draw participants also engage in commercial gambling activities, compared with 60 % of adults in the general population. This connection has raised concerns that prize draws may serve as a gateway to gambling, prompting calls for tighter oversight and clearer taxation rules.

Who is affected?

  • Online prize draw operators offering paid and free entry routes are directly affected. Those who have treated entry fees as exempt may face liabilities for under‑declared VAT and should review historic transactions.
  • Businesses using prize draws for promotions, such as retailers and charities, need to consider whether entry fees constitute taxable supplies. Promotional competitions based solely on skill may remain subject to VAT; free-entry draws with no paid option are outside the scope.
  • Large corporations are subject to the uncertain tax treatment rules. If their interpretation diverges from HMRC’s position, they must disclose the uncertainty.
  • Players and consumers are unlikely to see direct tax impacts, but operators may adjust ticket prices or limit paid entries to account for VAT.

Expert Analysis 

From a tax and accounting perspective, HMRC’s confirmation narrows the scope of the betting and gaming exemption. The key determinant is whether the consideration paid by participants is a stake in a game of chance (exempt) or payment for a right to enter a competition or prize promotion (taxable). Operators offering both free and paid entry routes effectively sell a participation right. HMRC’s position aligns with the principle that a competition with a free route is not a “bet” and therefore falls outside the Group 4 exemption.

Businesses that have relied on the exemption should assess their exposure. This includes analysing whether entry fees were treated as exempt and whether input VAT recovery on related expenses (such as prizes or marketing) was restricted. Where VAT was not charged, operators may need to correct past VAT returns and negotiate time‑to‑pay arrangements with HMRC. The UTT regime adds a further layer: taking a position contrary to HMRC’s known stance—such as claiming exemption after February 2026—must be disclosed if the potential tax difference exceeds £5 million.

Why this matters for UK businesses

For operators, the immediate impact of VAT treatment for promotional competitions is financial. Charging 20 % VAT on ticket sales could significantly reduce margins and may require price adjustments or reductions in charitable donations. Businesses that fail to account for VAT risk assessments, penalties and reputational damage. Those using prize draws as marketing tools must also be aware that VAT applies where participants pay to enter; free draws with no purchase requirement remain outside the scope. Compliance obligations extend beyond VAT; operators must implement the voluntary code’s player‑protection measures by May 2026.

The clarification also underscores the need for robust tax governance. Uncertain tax positions should be documented, and businesses should engage early with HMRC to seek confirmation or apply for rulings. Transparent communication reduces the likelihood of costly disputes. In the longer term, litigation may test whether the dual-entry draw model genuinely falls outside the betting exemption, echoing the successful “spot the ball” challenge. Until courts provide further guidance, conservative treatment and disclosure will be prudent.

VAT Treatment for Promotional Competitions: What Businesses Should Do

  • Review current and historic prize draw models to determine whether entry fees have been correctly treated for VAT purposes and identify any under‑declared VAT.
  • Distinguish between games of chance and games of skill. Where an element of skill predominates, treat the supply as taxable; where it is pure chance with a stake, exemption may apply.
  • Implement the DCMS voluntary code by 20 May 2026, including spend limits, age verification and restrictions on credit card payments.
  • Assess uncertain tax treatments and notify HMRC if the tax advantage exceeds the £5 million threshold, particularly if adopting a position contrary to HMRC’s statement.
  • Seek professional advice before launching prize promotions to ensure VAT compliance and mitigate potential liabilities.

How Apex Accountants Can Support Your Business with VAT on Prize Draws and Competitions

At Apex Accountants & Tax Advisors, we offer expert guidance on VAT and indirect taxes related to prize draws and promotional competitions. Our services include:

  • VAT Reviews: Assessing your prize draw and competition models to ensure they align with the latest VAT regulations.
  • Exemption Analysis: Determining whether VAT exemptions apply and evaluating any potential historic VAT exposure.
  • VAT Registration & Return Adjustments: Supporting VAT registration, filing adjustments, and handling negotiations with HMRC.
  • Voluntary Code Compliance: Assisting with the implementation of the voluntary code, including age verification and spend limits compliance.
  • Uncertain Tax Treatment Notifications: Offering expert advice on uncertain tax treatment and helping you prepare necessary documentation.

Contact us now to ensure your business remains VAT-compliant with the latest regulations.

Conclusion

The UK government’s confirmation that paid entries to prize draws are subject to standard‑rated VAT signals a shift in the treatment of a rapidly growing sector. With millions of participants and significant sums at stake, prize draw operators must reassess their tax positions and prepare for increased compliance obligations. The forthcoming voluntary code aims to improve consumer protections, and the uncertain tax treatment regime encourages transparency. Businesses that take proactive steps to review their prize promotions, implement the code and engage with HMRC will be better positioned to manage risks and avoid costly disputes.

FAQs About VAT on Prize Draws in 2026

Are online prize draws subject to VAT? 

Yes. HMRC has confirmed that prize draws offering both paid and free entry routes are not eligible for the betting and gaming exemption; paid entries must be charged VAT at 20%.

What about free‑entry routes? 

Where entry is genuinely free and no payment is required, there is no taxable supply and VAT does not arise. The tax liability applies to the paid entry, not the free option.

Why are games of chance usually VAT‑exempt?

Group 4 of Schedule 9 to the Value Added Tax Act 1994 exempts the provision of facilities for betting or playing games of chance. A game of chance is defined as one where chance or chance and skill combined determine the outcome. However, competitions based principally on skill are standard‑rated.

When does the voluntary code come into force? 

Signatories must fully implement the code within six months of its publication and no later than 20 May 2026. The code is not legally binding but demonstrates good practice and may influence regulatory expectations.

What is the uncertain tax treatment regime? 

Since 1 April 2022, large businesses with turnover above £200 million or assets exceeding £2 billion must notify HMRC when they adopt a tax position that is uncertain and exceeds a £5 million tax advantage. Adopting a position contrary to HMRC’s confirmed view on prize draws could trigger this notification.

Do prizes attract VAT? 

For exempt betting and gaming supplies, the stake money is outside the scope of VAT and prizes are not taxable; only the net takings are exempt. Where a prize draw is taxable, any input VAT on goods given as prizes may be recoverable, subject to normal rules.

Could future litigation change HMRC’s position? 

Possibly. The 2016 “spot the ball” case demonstrated that courts may classify certain competitions as games of chance. If a court were to decide that dual‑entry prize draws are bets or lotteries, they could become exempt. Until then, HMRC’s stated position applies, and businesses should account for VAT accordingly.

Are online prize draws subject to VAT in the UK?

Yes, when entry is paid. A paid entry fee to an online prize draw is consideration for a place in the draw and attracts VAT at the standard 20% rate. Free-entry prize competitions sit outside VAT altogether.

Why are games of chance usually VAT-exempt?

Betting, gaming and lotteries as such are VAT-exempt because the law treats the stake as participation in the gambling rather than payment for a supply. The exemption falls away when a promoter charges for entries to a draw that is not a regulated lottery.

Are Schools Closing Because of the Private School VAT Change?

Since the private school VAT change, effective 1 January 2025, private school tuition and boarding in the UK have been subject to 20% VAT, and from 1 April 2025 most charitable schools in England lost business rates relief.

This has shifted the question from “will fees rise?” to “can even larger schools cope?” Pressure is evident across the independent school sector. Pupil numbers in England fell between January 2025 and January 2026, and several schools were removed from the register in 2024. At the same time, new schools continued to open in 2025 and 2026, showing that the sector is both being squeezed and reshaped simultaneously.

How Schools Are Affected by the Private School VAT Change 

ChangeWhen It AppliedWhy It Matters
VAT on private school education and boarding1 January 2025Core tuition and boarding fees are now standard-rated
Prepayments caughtPayments from 29 July 2024 for terms starting on or after 1 Jan 2025Paying early did not always avoid VAT
Loss of charitable business rates relief (England)1 April 2025Many schools lost the 80% mandatory discount unless an exception applied

The business rates change is significant because charitable relief had previously reduced bills by 80%. Schools focused on pupils with EHCPs generally keep this relief.

A key point is that 20% VAT does not automatically mean fees rise by 20%. Schools can reclaim input VAT, leaving an average net VAT cost of about 15% of fee income. Average fee rises of around 10%, though some schools absorb more costs and others pass on more to parents.

Read: Everything About HMRC v Colchester Institute VAT Dispute 

Why Larger Schools Are Now Affected

The pressure isn’t just about one tax. In England, there are 2,474 private schools, of which 1,127 are charities. Around 1,024 of these schools lost charitable rates relief.

  • Average extra business-rates cost: £308 per pupil in 2025/26
  • For schools with over 1,000 pupils, per-pupil increase: £288
  • Total cash impact for large schools: £374,000 per school

Even though smaller schools face higher per-pupil increases, large schools still face significant total costs, especially with staffing, estates, and borrowing commitments.

Most schools will not immediately close. They may first:

  • Use reserves
  • Cut non-essential spending
  • Raise fees

Financial pressure can build over time before a school reaches a breaking point.

Are Larger Private Schools Actually Closing?

Yes, closures are happening, but context matters. 

  • 58 independent school closures in England in 2024
  • 85 closures in 2023
  • 63 closures in 2022

This includes voluntary closures and regulatory removals. VAT alone cannot be blamed. The impact of VAT is difficult to predict in terms of how many additional closures will result.

Since 2000, England has averaged 74 closures and 83 new openings per year, showing a natural turnover. The relationship between VAT and private school closures therefore needs to be viewed alongside this longer-term pattern. 

Larger schools are under more financial pressure, pupil numbers are down, and some bigger schools are no longer shielded from challenges previously felt mostly by smaller schools.

The picture since VAT took effect on 1 January 2025 is becoming clearer. Trade and government data indicate a rise in independent-school closures and mergers in the first VAT year, with around 105 schools closing or being absorbed by January 2026, while news tracking has recorded further closures through summer 2026, including schools that cited VAT alongside falling pupil numbers and other cost pressures. 

However, the government has rejected the idea that the policy has caused a sector-wide pupil exodus, pointing to continued school openings and broader demographic trends. Department for Education figures show that independent-school pupil numbers in England fell by 3.8% to 560,300 in January 2026, the second consecutive annual decline, even as the total number of independent schools has not collapsed. This suggests genuine financial pressure but does not establish VAT as the sole cause of either falling enrolment or individual school closures. 

What Schools and Parents Should Check

Practical steps matter more than headlines.

  • Check fee packaging: Bundled tuition may have one VAT treatment, while extras like meals or transport may be separate.
  • Understand exemptions: Nursery classes made up almost entirely of children under school age remain exempt. Care-based before- or after-school clubs can also stay VAT-exempt.
  • SEND placements: VAT applies to the fee, but local authorities can reclaim it when funding an EHCP placement.
  • Treat VAT recovery technically: Partial exemption and input VAT calculations are required for most schools.
  • Use official tools: Services like “Get Information about Schools” let parents compare school finances and performance.
  • Check registration fees: Application and registration fees are treated like normal tuition for VAT purposes.

Read: Getting Your Business Ready for the Summer’s Temporary VAT Cut 

How We Help Private Schools Deal With VAT

At Apex Accountants, we support independent schools with the practical side of VAT changes:

  • VAT registration reviews and timing checks
  • Partial exemption and input VAT recovery calculations
  • Fee structure reviews for tuition, boarding, meals, clubs, and bursaries
  • Cash-flow and budget modelling for VAT and business rates changes
  • Support on restructuring, mergers, and orderly closure planning

Conclusion

The biggest mistake is to reduce this story to a simple slogan. The evidence around VAT and private school closures shows a more complex picture. VAT and the loss of business rates relief have definitely increased pressure; pupil numbers in England’s independent sector have fallen for two consecutive years, and closures continue, but this does not isolate VAT as the sole cause and does not yet prove a clear wave of private-school closures in the UK. 

A more accurate headline would be this: larger private schools are no longer protected from the same financial pressures that have already hit smaller schools, but the official evidence still points to a sector in costly transition, not a one-line collapse story. 

FAQs on Private-School Closures in UK

When did VAT start on private school fees?

From 1 January 2025, with certain prepayments made from 29 July 2024 also caught if they related to terms starting on or after 1 January 2025. 

Does VAT on fees mean schools had to raise prices by the full 20%?

No. Official estimates point to an average fee rise of around 10%, not a flat 20%, because schools can reclaim input VAT on relevant costs. 

Is the business rates change a UK-wide policy?

No. VAT on fees applies across the UK, but the removal of charitable business rates relief applies in England. 

Are larger schools always hit harder than smaller ones?

Not necessarily on a per-pupil basis: in the matched cohort, schools with more than 1,000 pupils show a lower per-pupil rates increase than very small schools, but their cash increase per school is still large. 

Are nursery classes in private schools still exempt from VAT?

Yes, where they are wholly, or almost wholly, made up of children below compulsory school age. 

What about after-school clubs and holiday clubs?

Educational extracurricular activities are taxable, but childcare-based before- or after-school clubs and holiday clubs that consist of care are exempt. 

Can local authorities reclaim VAT on private school placements?

Yes, where the placement is funded by the local authority and the school is named in the pupil’s EHC plan, the local authority can reclaim the VAT through existing processes. 

Do bursaries remove the VAT charge?

Not usually. Where a separate bursary funds part of a specific child’s fee, VAT still applies to the full fee; only a school funding its own bursary to itself is outside scope. 

Are registration or application fees also charged?

Yes. Application and registration fees that must be paid for a pupil to attend are treated the same as normal school fees for VAT. 

Do official figures prove that VAT is already causing a wave of large private school closures?

No. Official closure data mixes voluntary closures with regulatory removals, and the policy impact note says it is difficult to assess how many extra closures the measure will cause.

How many private schools have closed since the VAT change?

Independent-school closures have risen since the 20% VAT on fees took effect in January 2025, with the sharpest increases among smaller prep schools. By January 2026, around 105 independent schools had closed or merged, with further closures reported during 2026. The government maintains the change has not driven a mass pupil exodus to the state sector, and each closure decision also reflects falling rolls and cost pressures that predate the VAT change. 

When did the 20% VAT on private school fees start?

1 January 2025. Fees paid from 29 July 2024 for terms starting on or after 1 January 2025 were also caught by the anti-forestalling rules, so early payment did not escape the charge.

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