Medical VAT Exemption Applies to Independent Doctor’s Assistant

• The Dutch Tax Administration’s VAT Knowledge Group concluded that medical services supplied by a self-employed doctor’s assistant can qualify for the medical VAT exemption, despite the assistant not being registered under the Individual Healthcare Professions Act.
• The services included blood collection, vaccinations, injections, wound care, triage, physical examinations and ECGs. The Knowledge Group considered that the activities had a therapeutic purpose and were qualitatively comparable to specific healthcare services supplied by a registered nurse.
• The conclusion took account of the assistant’s MBO-4 healthcare qualification, more than ten years of relevant experience and continuing professional education. The decision confirms that BIG registration is not the only route to exemption where equivalent professional quality can be demonstrated.

Extended article

The Dutch VAT Knowledge Group has concluded that medical services supplied independently by a doctor’s assistant fall within the Netherlands’ medical VAT exemption in the circumstances examined.

The individual worked as a self-employed doctor’s assistant for a healthcare centre and as a substitute assistant for several general practices. Her activities included blood sampling, finger-prick testing, urine testing, vaccination, administering injections, removing stitches, treating wounds, triage, physical examinations and preparing electrocardiograms.

The assistant had completed an MBO-4 healthcare qualification, had more than ten years of relevant experience and undertook annual continuing education. She was not herself registered under the Dutch BIG Act.

The Knowledge Group nevertheless concluded that the services qualified for exemption under Article 11(1)(g) of the Dutch VAT Act. The services had a therapeutic purpose and were performed in connection with diagnoses and treatment by general practitioners. They were also considered sufficiently similar in nature, scope and quality to specific medical services performed by a nurse.

The decision illustrates that the Dutch medical exemption can extend beyond services personally supplied by a BIG-registered professional. The relevant assessment includes the therapeutic purpose of the service and whether the supplier’s professional qualifications and experience assure a quality level equivalent to that of a recognised healthcare profession.

The outcome should not be read as a general exemption for all administrative or support services performed in a medical setting. The specific nature of the services, the connection with patient diagnosis and treatment, and the supplier’s professional competence remain central.

External sources:

• Medical VAT exemption for an independent doctor’s assistant
• Dutch Tax Administration overview of VAT exemptions.
• BTW Jurisprudentie