I am advised by Revenue that the VAT rating of goods and services is subject to EU VAT law, with which Irish VAT law must comply. In general, the VAT Directive provides that all goods and services are liable to VAT at the standard rate unless they fall within categories of goods and services specified in the Directive in respect of which Member States may apply a lower rate or exempt from VAT.
In accordance with the Directive the provision of facilities for taking part in sporting activities, including commercial watersports activities, are taxable at the second reduced rate, 9% and the supply of sports lessons including diving are generally taxable at the standard rate, 23%.
However, a VAT exemption applies to the supply of training and development courses, subject to the training and retraining being of a vocational nature. The VAT exemption may apply to sports instruction, such as diving lessons that are provided in the manner of vocational training or retraining that may lead to a recognised qualification as a diving instructor. Further information is available in Revenue’s guidance "VAT treatment of education and vocational training" found here:
www.revenue.ie/en/tax-professionals/tdm/value-added-tax/part03-taxable-transactions-goods-ica-services/Services/services-education-vocational-training-post-2015.pdf.