Revenue and Customs Brief 6 (2026) – VAT Liability of Locum Doctors

• HMRC’s Revenue and Customs Brief 6 (2026), published 17 July 2026, updates its position on the VAT treatment of past and present supplies of GMC-registered locum doctors, following the First-tier Tribunal decision in Isle of Wight NHS Foundation Trust v HMRC [2025] UKFTT 1114 (TC). [gov.uk], [gov.uk]
• HMRC now considers supplies of GMC-registered locum doctors may be exempt under Item 5, Group 7, Schedule 9 of the VAT Act 1994, including where supplied via an employment business. The exemption applies only to registered medical practitioners performing roles requiring such registration—not other healthcare professionals. [gov.uk]
• The brief explains how to claim refunds of overdeclared output tax for supplies within the last four years (using form VAT652, subject line “Locum doctors claim RCB 6/26”), how claims are handled, and the need for input tax adjustments under partial exemption rules. [gov.uk], [vat-valida…atfaqs.com]

Sources: GOV.UK – RCB 6 (2026) · GOV.UK full brief