Guide / Understand your financial position
Energy tax: establish the treatment of each supply, then the cost your school bears
Charitable status, residential use and fee-funded teaching raise different tax questions. Separate the VAT charged, the VAT recoverable and Climate Change Levy before comparing offers.
Start with three questions, not one school-wide label
For each supply, ask what VAT should be charged, how much of that VAT the school can recover, and whether Climate Change Levy applies. A correct answer to one does not settle the other two. The useful starting point is the legal customer, the activities served and the evidence behind the present bill.
This guide uses the current Great Britain fuel-and-power position and England school examples. VAT on private-school fees is UK-wide; the temporary electricity measure discussed here is for Great Britain. Northern Ireland and different legal arrangements need their own check. Use a competent tax reviewer for the school’s actual classification.
Distinguish the activity from the institution
Private-school education and boarding supplied for a charge have generally been subject to 20% VAT since 1 January 2025. That is the treatment of the school’s income. It does not automatically determine the VAT rate on the energy it buys.
HMRC identifies school residential accommodation within domestic qualifying use. Charity non-business use is a separate basis for fuel-and-power relief. Fee-funded education is a business activity even where the operator is charitable. A day school cannot rely on its charity registration as a complete explanation for a reduced energy rate. A bursary or subsidy also needs its actual payment arrangements checked; it does not, by itself, turn a fee-charging activity into non-business provision.
Prepare a practical activity map: teaching, boarding, staff residences, nursery, catering, pool, sports use, lettings and any separate trading activity. Then identify which supplies serve them. A label such as “boarding campus” is a prompt to investigate, not an automatic classification of every meter.
Apply the current rate to the evidenced supply
HMRC’s fuel-and-power notice, updated on 28 October 2026, confirms temporary zero-rating of qualifying electricity in Great Britain from 1 October 2026 to 30 June 2027. It did not expand which uses qualify. Qualifying gas remains subject to its own reduced-rate rules; other supplies may be standard-rated.
Small-quantity rules can also matter. HMRC gives average limits of 33 kWh a day (1,000 kWh a month) for electricity and 145 kWh a day (4,397 kWh a month) for piped gas supplied to one customer at any one premises. These are not a separate allowance for each meter. Ask the supplier or tax reviewer to check the customer, premises, quantities and billing period before relying on this route. Do not classify the supply from an isolated reading or an annual average alone. EV charging supplies are excluded from the small-quantity concession.
For mixed use, the notice provides a 60% qualifying-use test: at or above that share, the whole supply can qualify; below it, apportionment applies. The test concerns fuel or power use. Do not substitute a percentage of fee income, pupils or floor area without a supported method relating it to consumption.
A mixed-use certificate should identify the relevant premises and supply, the exact qualifying percentage and responsible sign-off. Retain the calculations and tell the supplier when qualifying use changes. New ownership, a closed boarding house or increased lettings may require a review. Incorrect certification can have financial consequences.
Recoverable VAT needs a second assessment
HMRC says private schools are likely to make taxable and exempt supplies. Input VAT connected with taxable supplies can be recoverable under the rules; non-business costs and exempt activities require separate treatment. Nursery, certain closely related services and other activities can affect the result.
The finance team should record the school’s agreed allocation and partial-exemption method, the period covered and the reviewer. Do not tell a provider to assume 100% recovery because the school is VAT-registered. Equally, comparing every offer gross can conceal a recoverable amount. Keep a cash view and a net-cost view together.
Check CCL and charging activities separately
CCL has its own exclusion and certification rules, including domestic and charity non-business use and mixed supplies. It is not removed simply because a school is registered for VAT, and recovering input VAT does not recover the levy itself. Ask the reviewer to reconcile the CCL basis with the activity and supply evidence.
A current check is needed where the estate has EV chargers. HMRC’s 28 October brief describes rules effective from 1 November 2026 for public and workplace charging. Such charging is not domestic use, including for the small-quantity concession. Residential charging and charity non-business use have distinct conditions. Give the reviewer the actual access and supply arrangements.
Leave with an accountable tax record
The TPI can help collect bills, meter schedules and supplier explanations. Establish whether it is also competent and contracted to provide tax advice. The bursar should know who reviews the conclusion and who updates the supplier’s records. A confident sales statement is not a substitute for that work.
Before comparing net prices, retain the tax assumptions beside the offer and flag anything unconfirmed. If the reviewer has not settled the treatment, show the uncertainty rather than entering an unsupported zero.
| Record | What to retain |
|---|---|
| Supply and activity | Legal customer, premises, meter and the uses it serves. |
| Supplier charging basis | VAT and CCL treatment, certificate, calculation and relevant dates. |
| School recovery basis | Allocation, partial-exemption method, recovery assumption and reviewer. |
| Next review | Change triggers, responsible owner and any unresolved question. |