Doctored VAT

I have taken on a new client who is a sole trader business working as a locum doctor on a self-employed basis for three different general practices. His annual sales are £120 000 and he is not VAT registered on the basis that he is providing exempt medical services. He charges an hourly rate for his services.

I have discussed the benefits of incorporation with him to save direct tax but am worried that the company would then be seen to be supplying his personal services to the practices. As far as I am aware this would mean that there is a standard rated supply of staff for VAT purposes rather than an exempt supply of medical services.

However on further consideration it then seems strange that there would be a different VAT outcome according to his chosen legal entity. I have read the HMRC public...