TC09534 - [2025] UKFTT 00594 (TC)

Based on the principles set out above, the issues which we need to determine in relation to Rushby, Jagers and Mrs Hilton are whether the subject matter of the classes taught is one which is commonly taught in a school or university and, even if it is, whether the classes provided by those three appellants were purely recreational.

Given the submissions made by Mr Marks, we also need to determine whether the classes offered by Rushby, Jagers and Mrs Hilton involved “tuition”, being the transfer of knowledge and skills from teacher to student.

As far as DCI is concerned, the only issue for determination is whether the classes taught by members of the LLP constituted private tuition in the sense that the members of the LLP were acting for their own account and at their own risk.