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HMRC internal manual

VAT Health

Transport of the sick and injured: Problem areas

The first problem area concerns our policy that exemption can only apply if the journey is to or from a place of medical treatment. This means that, if for example, a chronically ill person able to live at home moves to a new home (or goes on holiday) and requires specialist medical transport to do so in a specially designed vehicle, exemption is nevertheless, not available. Our policy to deny exemption in such circumstances may be contentious, as the person may be extremely ill; the vehicle may be equipped with the very highest specification emergency medical equipment; and the law does not specifically mention that the journey must start or finish at a place of medical treatment. But a line has to be drawn somewhere to prevent abuse of the relief which could happen if we relaxed the exemption. Such services are however, likely to form a very minor part of the overall activities of a company operating in this field and so taxable treatment is unlikely to take the supplier over the taxable turnover VAT registration threshold.

Another difficult area concerns supplies of an “ambulance” and crew to attend for example a public or sporting event. The difficulty here is in identifying what is being supplied. There is no exemption which applies specifically to first aid services and it can be difficult to draw the line between the supply of these services and the supply of transport services for sick or injured persons (to which exemption under item 11 might apply). It is vital that you examine the terms of the contract in detail. If the contract does not provide for any transportation to a hospital (or other place of medical treatment) then the exemption cannot apply. This means for example, that if a large team of first aiders were required to attend a marathon primarily to administer first aid, but would, in the case of any injury requiring hospital treatment, call for an emergency NHS or private ambulance, the supply of the first aiders services is clearly not covered by the item 11 exemption. Where however a crewed and specially designed vehicle is contracted to attend, for example a rugby match, and to be on standby, the item 11 exemption does apply even though the services of transporting the casualty may not be actually used.

You should not accept any attempt to artificially fragment the contract for example by separating exempt supplies of doctors and nurses from standard rated supplies of first aiders and exempt transport services. The contract should be viewed as a whole.