Christine Joy Hocking v HMRC

In Christine Joy Hocking v HMRC [2014] UKFTT 1034 – 12 November 2014 the FTT found that the teaching of pilates did not fall within the private tuition exemption.

Miss Hocking contended that the teaching of pilates should be exempt as the supply of private tuition ‘in a subject ordinarily taught in a school or university’ (VATA 1994 Sch 9 Group 6 item 2). She argued that pilates offers greater educational value than traditional sports as it requires a comprehensive understanding of the mechanics of the body.

For six years Miss Hocking had taught pilates for the BA Dance degree at the University of Surrey. Additionally the FTT accepted evidence that pilates is taught in many secondary schools in England (although no percentage was available) and as part of dance training courses.

Referring to Haderer (C-434/05) the FTT observed that to fall within the...