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HMRC’s new approach to the cosmetic medical sector

07 August 2023 / Guy Smith
Issue: 4900 / Categories: Comment & Analysis , VATA 1994 , Business , VAT
133185
Cosmetically complicated

Key points

  • HMRC has formed a specialist team to target the cosmetic medical sector.
  • Do certain treatments – such as Botox – qualify for medical exemption from VAT? HMRC’s position is that cosmetic treatments should be standard rated.
  • Consider the case of Illuminate Skin Clinics Ltd (TC8846): the First-tier Tribunal decided that the services offered were not exempt within the legislation and the appellant had not met the burden of establishing that it qualified for the exemption.
  • The main points to remember are to keep contemporaneous notes on each patient and to make reference to the International Statistical Classification of Diseases and Related Health Problems.

HMRC has recently formed a specialist team to target the rapidly growing cosmetic medical sector. The focus of attention is whether treatments such as Botox fillers or facial chemical peels qualify for medical exemption from VAT.

To put it simply HMRC’s position...

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