Transport of the sick and injured: Services performed wholly or partly outside the UK
Under subparagraph 2(1) of Schedule 4A to the VAT Act 1994, the place of supply of passenger transport services is where those services take place. Under item 4 (d) of Group 8 of Schedule 8 of VATA 1994, the transport of passengers from a place within to a place outside the UK, or vice versa, is zero- rated to the extent it is supplied in the UK. Zero rating applies irrespective of the carrying capacity of the vehicle, ship or aircraft.
An example of this might be where an unadapted minibus transports outpatients from Belfast to Dublin: the UK leg of the journey is supplied in the UK and is zero-rated. The Eire leg is outside the scope of UK VAT.
Further information on the place of supply of passenger transport services is contained in VATPOSTR2000