Case: is training care volunteers exempt from VAT?

Volunteers need knowledge to function in a working environment. Is training for that purpose exempt from VAT? The Dutch Tax Administration has published a knowledge group position on the point.

The situation

An umbrella organisation in the care sector holding a CRKBO registration offers training for care volunteers for a fee. The training aims to give volunteers the skills they need to look after the clients of a care organisation and to develop those skills. It is intended for volunteers, but employees sometimes attend as well.

Without the help of volunteers, the care organisation could not exist. A volunteer agreement sets out the description of duties, the option or obligation to attend training, provisions on confidentiality and liability, an obligation to be present for at least one or several half-days a month, arrangements for rostering and the start and duration of the agreement. Those provisions are comparable to those in an employment contract.

Is this training exempt vocational training?

Training volunteers for a fee through an organisation with a CRKBO registration can only be exempt where the training qualifies as vocational training for VAT purposes. Under Dutch policy that concept covers any form of education that trains for a specific occupation, trade or particular position, or that confers a particular ability to carry out such an occupation, trade or position, regardless of the age and educational level of those attending. It also covers courses aimed at how people function in a current or future working environment. Education aimed primarily at skills in one's personal life is not covered.

The terms "particular position" and "working environment" are not defined in the policy and must therefore be given their ordinary meaning in everyday language, having regard to the context and purpose of the exemption. A position is an office, post, working environment or job. A working environment is the whole set of circumstances in which someone works and the objects of that work.

The knowledge group's position

According to the Dutch Tax Administration, the training can be treated as exempt vocational training, because it is aimed at imparting or maintaining the knowledge a volunteer needs to function in a working environment. Professionals and volunteers work together in the same business setting, and the volunteers do not carry out their work in their personal lives. They form part of the working environment, because they work in circumstances comparable to those of the professionals, care for clients, and because their work is needed for the continuity of the organisation's services.

Why this matters in practice

The position shows that the exemption for vocational training is not limited to education for current or future employees, but can extend to training volunteers. Think of volunteers in a hospital, nursing home, hospice or school. The training must, however, be aimed at functioning in a working environment.

Note that in the case put to the tax authorities the training was delivered by an institution with a CRKBO registration. That registration is a condition for offering vocational training VAT-exempt.