United Kingdom Updates Guidance on VAT for Locum Doctors

Summary

• HMRC has added a reference to Revenue and Customs Brief 6 (2026) to VAT Notice 701/57 concerning health professionals and pharmaceutical products. The Brief addresses supplies of GMC-registered locum doctors. [Daily upda…or: Brexit | Outlook], [gov.uk]
• HMRC now accepts that qualifying supplies of GMC-registered locum doctors may fall within the VAT exemption, including where the doctor is supplied through an employment business. The position does not extend automatically to other medical staff or general staffing services. [gov.uk]
• Affected suppliers may be able to claim repayment of output VAT overdeclared during the previous four years. Claims remain subject to conditions including unjust enrichment, partial exemption, evidence and correct VAT treatment throughout the supply chain.

Extended article

HMRC’s Revenue and Customs Brief 6 (2026) sets out its revised position following the First-tier Tribunal decision in Isle of Wight NHS Foundation Trust v HMRC.

Item 5, Group 7, Schedule 9 to the VAT Act 1994 exempts the provision of a deputy for a registered medical practitioner. HMRC now accepts that supplies of GMC-registered locum doctors can fall within this provision, including supplies made through an employment business. [gov.uk]

The exemption is narrowly framed. It applies where the person is GMC-registered as a medical practitioner and performs a role that must be carried out in that professional capacity. It does not cover general staffing services or other healthcare professionals merely because they are subject to professional registration.

Suppliers that previously accounted for output VAT may be entitled to submit correction claims covering supplies within the preceding four years. Input VAT and partial-exemption consequences must also be considered.

Official external sources: HMRC Revenue and Customs Brief 6 (2026) and HMRC’s detailed locum-doctor VAT guidance. [gov.uk], [gov.uk]

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