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HMRC internal manual

VAT Health

HM Revenue & Customs
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Nurses, midwives and health visitors: Nursing services supplied to institutions approved under item 4 of Group 7

VATHLT3000 contains detailed information on the extent of the exemption under item 4 for nursing services provided by a hospital or other state-regulated institution. We have outlined below however, the exemption as it applies to both registered and unregistered nursing services, subject to the purpose test being met.

  1. Registered nurses. The supply of services by registered nurses, midwives and health visitors are considered to meet the purpose test and are exempt from VAT under item 1 (d) wherever they are performed (in the UK).
  2. Unregistered nurses. The supply of services by a nursing auxiliary (or other similar unregistered nursing personnel) is not exempt under item 1 as there is no statutory register. They must charge VAT at the standard-rate when they supply their services to individuals in their own homes or in establishments which are not approved, licensed etc under Item 4 of Group 7. Their supplies may however, be exempt when supplied to institutions approved, licensed, registered etc under item 4 of Group 7 whether supplied by the auxiliaries themselves or by an agency acting as principal provided their services form part of the care made to the patient. (This will apply to supplies made to an NHS hospital even though its provision of care to patients is non-business and outside the scope). The rationale for this stems from the Tribunal decision in “Crothall and Company Limited” (VTD 6). VATHLT3000 contains a full explanation of the Crothall Tribunal and its relevance to the application of exemption under item 4.