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VAT Tribunal decides that college attached to a University is within the VAT education exemption

25 June 2025

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Solent Pathway Campus Ltd is a Joint Venture between Solent University and another company. Students obtain a foundation award at Level 3 of the National Qualifications Framework, equivalent to year 1 of a degree with Solent University but the college did not offer degree level courses.

The question was whether the body was a “college” of the University and therefore within the scope of the VAT education exemption.  The Tribunal rejected HMRC’s suggestion that it was not a formal college or school of the University; if HMRC had been successful VAT would have added to all college fees.   

If you wish to discuss this in further detail, please get in touch with one of our Indirect Tax Services team members here.