The taxpayer’s business was set up by a chartered accountant to improve access to healthcare based on their own experiences. At the clinic qualified nurses administered intravenous vitamin drips and vitamin injections to customers. The taxpayer initially took the view that its supplies qualified for zero rating as goods dispensed to an individual for personal use based on the prescription of a doctor. It registered for VAT and submitted a repayment return that was challenged by HMRC.
HMRC considered the supplies were exempt as a medical treatment under VATA 1994 Sch 9 Group 7 Item 1 ie the aim was to protect maintain or restore the health of the customers. After a review the department decided that the fees were standard rated on the basis that there was no evidence of customers having any illnesses or diseases that required treatment. The taxpayer’s website focused on...
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