VAT Exemption for Dance Lessons – CAA Lyon, November 20, 2025 (No. 24LY01287, M. A.)
A sole proprietorship operated by a dance teacher underwent a tax audit. The tax authorities challenged the VAT exemption applied to dance teaching services.
Applicable Rules:
- Article 261, 4-4° b of the French Tax Code (CGI):
Lessons or courses related to school, university, professional, artistic, or sports education, provided by individuals who are paid directly by their students, are exempt from VAT. - Court Interpretation (CAA):
Only lessons provided personally by the teacher qualify for the exemption.
→ If the teacher uses other individuals to deliver lessons, the exemption does not apply.
Case Details:
- Some lessons were taught by other instructors, paid through fee-sharing arrangements.
→ In principle, these lessons are not VAT-exempt. - Administrative Doctrine (BOI-TVA-CHAMP-30-10-20-50 §370):
VAT exemption is allowed if the activity is carried out without any employees, even if the teacher has a dedicated studio.
→ The teacher had no employees.
CAA Decision:
- The teacher could rely on the doctrine (Article L.80 A of the Tax Procedure Code) to exempt the lessons personally taught by them from VAT.
- Lessons taught by other instructors remain subject to VAT.
Key Takeaways for Practice:
- VAT exemption for artistic or sports lessons is strictly personal.
- Involvement of other instructors (even without an employment relationship) jeopardizes the exemption.
- The doctrine provides a tolerance when there are no employees, but only for lessons taught by the teacher themselves.
Source Legifrance.gouv.fr
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