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Does a Medical Practitioner provide Medical Service for VAT Purposes or not?

HMRC have attacked a number of medical practioners who supply their services via limited companies to private health care providers, agencies and the NHS on the basis that the company is not providing a supply of VAT exempt health care, but instead is simply providing a supply of “staff”. This stance understandably causes concern for medical practitioners that make supplies via Limited companies and who simply cannot understand why VAT exemption does not apply given that they are registered medical practitioners and clearly employed to care for patients.