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HMRC internal manual

VAT Health

HM Revenue & Customs
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Transport of the sick and injured: How to determine whether exemption applies

How to determine whether exemption applies

There are three conditions which must be satisfied before exemption can apply. These are:

1. the passengers transported must be “sick or injured persons”
“Sick or injured persons” in this context should be interpreted as meaning persons in need of, or having just received, medical care or treatment;    
  2. the transport must form part of a journey to or from a place of medical treatment
Clearly, the emergency transport of casualties to hospitals in emergency “blue light” ambulances is covered by the exemption, and transporting the sick or injured to or from a hospital, clinic, or nursing home is also covered. The journey may not be an emergency - it may simply be to attend hospital for tests, or an operation, or it could be the journey home after such treatment. Where the transport supplied forms part of a journey to or from a place of medical treatment, but does not in itself begin or end at the place of treatment, the exemption nevertheless applies if all other criteria are met. For example, the service of transporting a person injured at sea by a (specially designed) helicopter only so far as a conventional ambulance to complete the journey to hospital by road, will still be exempt; and    
  3. the vehicle in which the person is transported must be “specially designed” for the purpose of providing such transport
The exemption is not restricted to road vehicles, and can apply in principal to helicopter air ambulances and other forms of rescue transport. However to qualify as “specially designed” any vehicle must have the facility to secure a recumbent person on a stretcher or be fitted with a ramp or a lift, and clamps sufficient to enable a person in a wheelchair to be safely wheeled on, transported in, and wheeled off the vehicle. Many vehicles which are regarded as ambulances have not been “designed” in the pure sense (i.e. from inception) as such. In many cases a standard shell of a vehicle will be taken and adapted to be suitable for carrying sick or injured persons. We accept that if these adaptations meet the above description they are sufficiently significant to make the vehicle, for practical purposes, “specially designed” within the meaning of item 11.