Bell’s College v HMRC

In Bell’s College v HMRC [2015] UKFTT 176 (25 April 2015) the FTT found that some of the courses provided by Bell’s fell within the education exemption.

Bell’s was a private college approved to offer Education Development International qualifications. It offered vocational courses such as English for Speakers of Other Languages (ESOL) painting and plumbing.

The FTT found that Bell’s was not a ‘school’ providing ‘secondary education’ by reference to the definition in the Education Act 1996. The FTT noted that the fact that the college offered work placements to under 16s did not make it a ‘school’. Furthermore the courses offered by the college were either part time or too specialised to constitute ‘education’.

Bell’s was not a ‘college or university’ either as it was not integrated by any university. The arrangements it had with several universities which ensured...