The second of three. Last time I ended with Haliburton’s sailor, who comforted a friend with the thought that this life ain’t all beer and skittles. My mother had her own version of that consolation, and hers had an edge. ([Part one](https://jameswilding.blog/2026/10/20/life-is-not-all-beer-and-skittles-how-josephine-wilding-bridged-ucl-mit-and-the-drawing-room-fire/))
My mother had a phrase for the unevenness of things. When fortune appeared to smile on one child while another carried a heavier load, or when effort went unrewarded and the scales tipped without obvious reason, she would offer a small, knowing smile and say, “Impartial injustice to all.”
She was a practical Catholic, the sort who had once taken herself off to study linguistics at MIT for nine months while the rest of us carried on at home, who helped build a parish church, and who still found time to remind her sons that the world had never been designed as a perfect ledger. Equality of outcome was not the promise. The Fall had seen to that. Original sin, the crooked timber of humanity, the simple fact that gifts and burdens are handed out without consulting any committee—these were the given conditions of the journey rather than grievances to be endlessly litigated.
Her remedy was older than any white paper. “Offer it up,” she would say. Not as resignation, and certainly not as permission for real injustice to go unchallenged where it could be challenged, but as a deliberate act: take the sting, the disappointment, the sense that the arrangement is unfair, and present it quietly as something that might, in the mysterious economy of grace, spare someone else a longer stay in purgatory. Waste less time resenting the unevenness. Convert it, if you can, into something useful.
I grew up watching that instruction put into practice on the long drives down to Capel. My grandmother Helena—Grannin to my brother Hugh and me—lived in a grace-and-favour, almost derelict rambling country pile known as Taylors, near Dorking. In the early 1960s there were no bypasses worth the name. The journey from Maidenhead involved traffic lights, endless queues, and a good three hours on high days and holidays; even now the same route can take the better part of two. We would pile into the red-and-white Hillman Husky estate, often with an odd spare boarder whose parents could not collect him for half-term, and set off. Somewhere after an hour the narcolepsy that afflicted my mother—and more severely her brother John—would hit hard. She would pull into a patch of woodland, tell the boys to get out and run around for twenty minutes while she slept, and answer our predictable complaints with the same calm phrase. “Offer it up.” Or, with a dry half-smile, “Better ten minutes late than dead on time.” It was a comforting thought, even if we did not always recognise it as such at the time.
She woke when the twenty minutes were up, and we drove on to Taylors. Sixty years ago, in the days before safety belts and air bags in cars, nobody would have thought twice about letting good kids run around in a strange, edge-of-settlement coppice while the driver had a snooze. We were wary, mind you, but exploring was an opportunity drilled into us by our reading books, whether by Enid Blyton, E. H. Shepard or Geoffrey Willans. We knew that adventures always needed to be had!
I notice now how little of that day was about the road. The narcolepsy, the boarder whose parents couldn’t collect him, the three hours in the queue all landed on us in turn, and none of it could be argued with. Nobody held a meeting about it.
When I look at English education today I hear her voice again, with one qualification. Her phrase is about fortune, and nobody sets fortune. A tax is different, because someone chose it. A judge, or a minister, is not allowed to let the unevenness of the world bend the verdict, and that is the argument I take from James Bruce, Professor of Philosophy at John Brown University, below. It is where my mother’s acceptance stops and my objection starts. VAT has been laid on one kind of schooling and left off its near neighbours, nurseries, universities, private healthcare and regulated care among them. That unevenness was chosen, so it can be defended or fixed.
I am about to propose an arbitrator of my own, so please read the rest as a warning to myself about clever instruments.
***
This week the Prime Minister called the number of young people not in education, employment or training a “moral failure”. I will come back to that in the last of these three posts, once Alan Milburn’s final report is out after the Budget. I mention it here because NEET status has no interest in a family’s income, its postcode or the school its parents did or did not choose. It lands on rich and poor alike, and any serious policy has to start by ignoring everything except the young person in front of it. That is exactly the discipline I want to apply to the tax on school fees.
Those who do not move do not notice their chains. The line is long attributed to Rosa Luxemburg, with a footnote to follow on that. Independent schools have been moved since January 2025, and the chafing is now easy to see.
James Bruce’s essay on impartiality in *Religion & Liberty*, which I read recently, says justice asks two things of us. We should ignore what ought to be ignored, and we should attend to what matters. The King James Bible puts the first half of that bluntly: “Thou shalt not respect persons.” The second half is the one I had underrated. A bribe blinds a judge, but not only by making him favour the wrong man. It stops him seeing the alibi that is sitting in front of him. Bruce gives the example of a parent who promised a reward for chores and then finds the reward inconvenient. The parent doesn’t lie. He just stops looking at the facts that are in the child’s favour.
Apply the two questions to VAT on fees. What should be ignored? The wealth of some families, the political convenience of a visible target, and the tribe the policy is aimed at. What should be remembered? The nature of the service and the consequences of taxing it.
The nature of the service is the trouble, as I said above. Only day and boarding education for children of about five to eighteen has been picked out, while its close cousins stay exempt. A tax on discretionary spending would be a coherent thing, but this one makes it a tax on a particular target.
The consequences are also now visible. Cairneagle’s analysis of the latest DfE and ISC data finds that since the last full year before VAT, enrolment at mainstream independent schools in England has fallen by 40,197 pupils, or 7.5%. Falling birth rates are part of the story, but they explain only about a third of that decline. The rest is a loss of market share, with VAT the principal driver. The falls have been steepest at the entry points: among eleven-year-olds the fall was 6.9% in independent schools against 1.9% in state schools, and the number of new joiners to ISC schools fell 6.1% in a year. When government sets independent fees against state per-pupil funding, the comparison rarely includes the long-term costs of the state estate, such as capital spending and residual PFI liabilities. Marking your own homework is rarely an exact science.
The children who move still need places. The state sector is unevenly distributed, and housing markets capitalise school quality, so a good state place is partly bought through a postcode premium. Taxing one slice of private provision resolves none of that.
My proposal does not ask the Treasury to give up revenue. A government-appointed arbitrator would establish a transparent, full-cost figure for delivering primary, secondary and sixth-form education to eighteen, and a parallel figure for state boarding. The stated cost of a state place, currently £8,580 for a pupil aged 5 to 16, covers revenue funding only. It leaves out the capital cost of the buildings and grounds, so it understates what a place really costs. My own starting estimate for the full cost is a total somewhere between £11,000 and £14,000 a pupil. The range is wide because schools differ in how they were built. A school rebuilt under PFI carries financing charges that a school built or refurbished with direct capital funding does not, and those liabilities are still on the state’s books. An arbitrator would have to decide how to treat that variation, which is one more reason the method must be published. That figure becomes the VAT-exempt part of any fee, and tax is charged only on what a school charges above it. Input tax would be recoverable only in proportion to the taxable part of the fee.
A hypothetical shows how it would work. Suppose the arbitrator settled on £12,500, within that range. Parents choosing a school that charges £13,000 would pay tax on £500 for each place taken. At 20% VAT that is £100 a place. Parents choosing a school that charges £25,000 would pay tax on £12,500 for each place, which comes to £2,500. The first school is no longer treated as if it were the second. Under the present rules the same tax would be £2,600 and £5,000 a place. Every family saves £2,500, but that removes almost all the tax at the lower-fee school and only half of it at the higher-fee one. The tax follows the premium element of the fee, and a school charging above the baseline has to justify to the parents who pay it what that premium buys, which is a sensible incentive for any school to face.
The Treasury does not lose all of that VAT. A school can currently reclaim the VAT on its own costs, such as building work, energy and equipment. Under this proposal the part of the fee covered by the state allowance becomes exempt, and the school could no longer reclaim input VAT on the share of its costs that relates to it. The Treasury would therefore keep that money, and the net loss to it is smaller than the VAT forgone on the headline fee.
Sixth form colleges are the Cinderella of the state system. They take young people at sixteen and give them a serious, well-regarded route into university, training and work, and they do it on less money than anyone else in the 16 to 18 sector. Projected funding per student in 2024–25 is about £5,500 in a sixth form college, against £5,900 in a school sixth form and £7,350 in a further education college. In real terms, sixth form college funding is 15% lower than a decade ago. I recommend that the VAT raised on the premium element of fees be directed to those and the wider further education college provision. For comparison, the national base rate for 16 to 19 education in 2025–26 is £5,105, while state schools receive £8,580 per pupil aged 5 to 16 in 2026–27, revenue only. The £11,000–£14,000 full cost I would expect an arbitrator to find, once capital is included, sits well above all of these, which exclude it. The whole of the state sector has been squeezed hard, and the colleges are no exception. A premium-fee contribution would put money behind the institutions best placed to support the growing cohort of NEETs, and I’d argue that is a better use of it than a general addition to the Treasury’s receipts.
The weak point is the figure itself. Whoever sets it will be accused of setting it too low by one side and too high by the other, so the arbitrator would have to be independent in fact, and the method would have to be published and open to challenge. I would rather argue about a published number than live with a boundary nobody can explain.
It would not cure every inequality. It would replace an arbitrary line with one that can be defended: the state defines and funds a core entitlement at a transparent cost, and amounts charged above that are treated as discretionary and taxed accordingly. That is closer to impartiality than what we have now, and Bruce is right that nobody can know in advance whether it will favour their side. I think that is a reason to try it.
*Sources: [Bruce, “Justice, and Only Justice”, Religion & Liberty](https://www.acton.org/religion-liberty/volume-33-number-3-4/justice-and-only-justice-beauty-impartiality-and-ugliness-her); [Cairneagle, “Independent school enrolment trends”, 8 October 2026](https://www.cairneagle.com/independent-school-enrolment-trends/); [Morning Advertiser on Burnham and NEETs](https://www.morningadvertiser.co.uk/Article/2026/10/19/burnham-vows-welfare-system-overhaul-to-help-young-people-into-work/); [Parliament written evidence on 16–18 funding](https://committees.parliament.uk/writtenevidence/139181/html/); [NEU on the 2025–26 funding rate](https://neu.org.uk/advice/member-groups/further-education-teachers/funding-16-19-education); [DfE school funding statistics](https://www.explore-education-statistics.service.gov.uk/find-statistics/school-funding-statistics)
*Footnote (my original post on Rosa Luxemburg can be found here https://jameswilding.blog/2013/02/20/those-who-do-not-move-do-not-notice-their-chains-rosa-luxemburg/): On reflection, and after some correspondence over the years questioning the source, I should note that this quotation appears to be apocryphal — no primary citation in Luxemburg’s own writing has been traced, and it seems to be a later amalgamation, gathering pace especially in the Cold War period and after, that stacks her ideas about praxis revealing the nature of oppression alongside Marx’s “nothing to lose but their chains” language from the Manifesto. The sentiment is consistent with her actual arguments about consciousness emerging through action rather than reflection alone — but the neat line itself likely isn’t hers. The argument of this post stands independently of the attribution.
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