I have been approached by a potential client, H&W karate teachers trading as a partnership. The classes are either taught by the proprietors on their own, or they sometimes teach alongside another qualified teacher or helpers. They have been treating their supply as exempt.
Reading the VAT education manual I am unsure the VAT exemption applies - it states
In principle, private tuition is exempt when supplied by either a sole proprietor or any member of a partnership. The exemption does not extend to instruction delivered by anyone employed or engaged to help. In these circumstances, the sole proprietor or partnership may opt to use any fair and reasonable method to apportion their supplies between exempt and taxable elements. If this is impractical, they may treat all their supplies of tuition as taxable, regardless of who actually delivers it. If a sole proprietor or partnership employs or engages others in a non-teaching capacity, this has no effect on the liability of the tuition they themselves supply.
So here the instruction is not "strictly" delivered by someone else, but neither are the helpers in a non-teaching capacity. Would you say the supply is exempt?
Thanks for your input!