In certain circumstances, supplies of goods or services which are closely related to a supply of education can also benefit from the exemption. ‘Closely-related supplies’ are goods and services which are for the direct use of the student and necessary for delivering the education to that person. They can include accommodation, catering, transport and school trips.

The extent of the exemption for closely related supplies is currently being litigated. In the case of Brockenhurst College, the Tax Tribunals decided that income received from the supplies of meals from its restaurant where it trained students were exempt from VAT, as was the income from performances by students studying for dramatic arts qualifications. HMRC appealed: in HMRC v Brockenhurst College [2015] EWCA Civ 1196 the Court of Appeal concluded that, on the facts before it, the interpretation and application of the exemption in Article 132(1)(i) of the Principal VAT Directive (2006/112/EC) was not acte clair and decided to make a reference to the CJEU for an opinion.