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HMRC internal manual

VAT Relief for Disabled People Manual

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HM Revenue & Customs
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Parts and accessories [item 2(h)]

Conditions to be met under item 2(h)
What is a part?
What is an accessory?
Are parts and accessories ‘designed solely’ for use in or with qualifying goods?

Conditions to be met under item 2(h)

For parts or accessories to benefit from zero-rating under item 2(h) (see VRDP05100):

  • the basic preconditions for item 2 (see VRDP05000) must all be satisfied;
  • the parts or accessories must be for goods which qualify for zero-rating in their own right under items 2(a) to 2(g); and
  • the parts and accessories must have been designed solely for use in connection with those qualifying goods.

What is a part?

See ‘Notice 701/7 Reliefs for disabled people’.

What is an accessory?

See ‘Notice 701/7 Reliefs for disabled people’.

Are parts and accessories ‘designed solely’ for use in or with qualifying goods?

Examples of parts and accessories eligible for zero-rating are:

  • the foot rest for a wheelchair could be zero-rated because it clearly has no use other than in connection with the wheelchair and so passes the ‘designed solely’ test; and
  • a replacement lever for a chair lift.

Examples of parts and accessories not eligible for zero-rating are:

  • standard batteries supplied for use in an invalid scooter; and
  • a mobile phone supplied for use in a qualifying vehicle.

The issue of whether products could be considered as parts and accessories featured in the following Tribunal cases:

  • The Princess Louise Scottish Hospital (1412);
  • Ian Mills (1893);
  • Alec C Wesley (9074); and
  • Poole Shopmobility (16290).

The Princess Louise Scottish Hospital (1412)

The Appellant proposed as one of the arguments for zero-rating the supply of overbed tables that they were eligible under 2(h), as parts and accessories designed solely for use in or with the goods in 2(b), namely ‘electrically or mechanically adjustable beds designed for invalids’. The Appellant argued that the table conformed in every respect with the various positions of the bed and had obviously been designed by the same designer, but the Tribunal dismissed the appeal, stating that:

“This is not, however, the same as saying that the table was designed solely for use with the bed, and indeed, the table is not included in the list of matching accessories for the beds…”

Ian Mills (1893)

The appeal concerned a decision of the Commissioners that the supply of a generator was liable to VAT at the standard rate. The generator was acquired to ensure an electrical supply to enable Mr Mills’ daughter, Nicola, to use her nebuliser in the event of a power cut. The Commissioners submitted that generators are portable power sources and so were not designed solely to operate a nebuliser. The Tribunal agreed, concluding that:

“… the brochure put out by Honda UK Limited indicates that the advertised uses are both domestic and light industrial, and there is no mention therein of any equipment or appliances designed solely for the handicapped.” It also dismissed the Appellant’s contention that the black box constituting the nebuliser and the generator together constituted equipment or an appliance designed solely for use by a handicapped person, holding that they were “separate and distinct chattels, and are not supplied together as one unit”.

Alec C Wesley (9074)

This case concerned a portable generator providing power to a stair lift in the event of a failure in the mains power supply. The generator was an all-purpose electric generator which could be used other than for the operation of the stair lift.

Poole Shopmobility (16290)

In this case the Tribunal considered whether the batteries for wheelchairs and mobility scooters are eligible for VAT relief. The appellant argued that the batteries are integral parts of the vehicles. The Chairman decided:

“The batteries are ‘all purposes’ batteries. They are used in a much wider range of appliances and vehicles than simply scooters and wheelchairs for the disabled.”