VAT implications for digital training and events supplied by charities and non profit organisations

In common with businesses generally, many charities and non profit organisations are now supplying training, education and events online. This reflects rapid developments in digital technology and recent changes in the way that customers access these services. They are now likely to 'tune in' online, so a UK-based organisation can supply these services to businesses or consumers anywhere in the world, which can create unexpected VAT issues.

What is an Electronically Supplied Service (ESS)?

An ESS is a digital service automatically delivered via the internet or an electronic network, with minimal or no human intervention needed to supply it to the end consumer. All e-services supplied in this way are categorised as digital services. ESS include access to virtual events, such as live-streamed educational seminars and conferences, online learning courses or downloadable information. Supplies of ESS to UK customers follow the normal VAT rules, but for overseas customers the rules vary depending on whether they are supplied to businesses or consumers.

B2B or B2C

Business-to-business (B2B) transactions involving ESS and overseas customers do not usually give rise to any consequences for the UK supplier, as the recipient is obliged to account for any VAT due in their own jurisdiction. However, the same does not apply to business-to-consumer (B2C) transactions. Most countries now treat B2C supplies of ESS as being supplied where the consumer belongs and therefore subject to VAT in the consumer’s country, giving rise to a potential liability for a UK supplier to account for VAT in that country.

European Union (EU)

The UK applies a narrow definition to ESS and does not currently include access to virtual events, such as a live-streamed educational lecture or seminar. However, the EU changed its rules in January 2025 and does treat access to virtual events as ESS. This means that a UK supplier providing educational courses or seminars online to B2C customers in the EU may have a liability to register for VAT in each of those EU countries. It should also be noted that the VAT threshold for a non-established or foreign supplier, including UK suppliers, is nil throughout the EU, so the first such supply can create a liability. UK organisations can take advantage of the One-Stop Shop (OSS), which allows for a single VAT Return to be completed for all 27 EU countries, but understanding this before making any such supplies would be beneficial.

Rest of World (ROW)

Outside of the EU, the landscape in ROW countries is similar in that most of them now have a VAT or GST (General Sales Tax) system in place, and many of those treat B2C supplies of ESS, including access to virtual events, as subject to VAT where the consumer belongs. As such, the supply of ESS to B2C customers based overseas can give rise to a liability to register for VAT in multiple countries and some jurisdictions, such as the US and Canada, may also require state or provincial registrations to be completed. In common with the EU, ROW registration thresholds are usually nil or relatively low, so supplies should be closely monitored.

All organisations supplying virtual events, educational seminars or online learning should review their supplies in terms of whether they would be regarded as an ESS and, in particular, the place where their customers are located.

For further information on any of the above, please contact your usual Crowe contact.