Private school VAT is £0 at current law although fees bear VAT from 1 January 2025 #2318

private_school_vat multiplies pupils × mean fee × the share of fees bearing VAT × gov.contrib.labour.private_school_vat. That rate is 0 for all time, so the head is £0 at current law (measured £0 on policyengine-uk-data 1.58.0 for 2025 to 2030).

VAT has applied to private school fees since 1 January 2025. Finance Act 2025 s.47 inserts Part 3 into VATA 1994 Sch 9, taking education, vocational training and closely related board and lodging supplied by a private school out of the Group 6 exemption. Section 49 gives it effect for supplies on or after 1 January 2025, so the fees bear the standard rate.

• https://www.legislation.gov.uk/ukpga/2025/8/section/47/enacted
• https://www.legislation.gov.uk/ukpga/2025/8/section/49/enacted

The general vat head does not carry this charge. Its full-rate share (full_rate_vat_expenditure_rate) is trained on ETB VAT paid in FYE 2024 (policyengine-uk-data datasets/imputations/vat.py), when the fees were exempt, and it does not vary by year.

The fix:

• Model the statutory charge with a baseline parameter outside contrib.
• Keep the contributed reform rate without letting it charge the fees twice.
• Update the fiscal partition (Count corporate SDLT once and let SDLT abolition remove all of it #2235) to match.