Article

HMRC launches investigation into private schools over prepayment of fees

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4th November 2025 5 min read

From 1st January 2025, most private school fees became subject to VAT at the standard rate of 20%, following the removal of the VAT exemption for education and boarding services provided by private schools.

In anticipation of this change, some schools offered the option to prepay fees before the legislation took effect, aiming to avoid the additional VAT charge.

HMRC response

HMRC is now investigating whether the advance payments of fees made from 29th July 2024 are caught by the anti-forestalling provisions introduced alongside the VAT measure. The aim is to prevent arrangements designed to avoid VAT.

These provisions state that if a school invoices or receives payment on or after 29th July 2024, but before 30th  October 2024 for a term starting on or after 1st January 2025, VAT will be due on the first day of that term.

What schools should do

If your school received any prepayments between 29th July and 30th October 2024, and you’re uncertain about the VAT treatment or liability, we strongly recommend seeking professional advice. HMRC’s anti-forestalling rules are complex and may apply even if payments were made before the legislation formally came into force.

Our team can help you review any potentially contentious income, assess your exposure, and ensure your arrangements are fully compliant with current VAT guidance. Please get in touch if you’d like support navigating this issue.

Get in touch

About the author

Ali Garner

Indirect Tax Manager

I’m Ali, I’m an Indirect Tax Manager based in the Derby office. I joined PKF Smith Cooper in June 2025 to support the growing Indirect Tax team on a range of clients and projects. The world of VAT and Indirect Taxes can be complex and no two projects are the same, Lord Justice Sedley said it best in the case of Royal & Sun Alliance, “it’s a kind of fiscal theme park in which factual and legal realities are suspended or inverted”, and I do love a theme park!