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VAT liability of school holiday clubs

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Revenue & Customs Brief 18/2020 clarifies HMRC’s policy on the VAT treatment of school holiday clubs. In essence, where the predominant element of the holiday club is the provision of childcare rather than activities provided to the children and parents, the supplies will fall within the welfare exemption. This follows the decision in RSR Sports Ltd [2019] UKFTT 678 (TC), where the First-tier Tribunal found that the predominant element of the holiday camps was childcare.

HMRC will in future distinguish between activity-based clubs and those which exhibit the following key features:

  • the members of staff are merely supervising activities and do not hold any coaching or teaching qualifications;
  • there is no external standard to which the services are being provided; and
  • the activities are merely an adjunct to the essential service which is childcare.

The brief also invites anyone who considers that they have received an incorrect ruling prior to the decision in RSR to seek a corrected ruling and a refund of any tax incorrectly overpaid.

Issue: 1511
Categories: News