Umbrella company did not supply exempt medical care
In Mainpay Ltd v HMRC[2022] EWCA Civ 1620 (9 December 2022) the Court of Appeal (CA) held that supplies made by an umbrella company which employed consultants and GPs did not fall within the VAT exemption for medical care and were instead taxable supplies of staff.
Mainpay employed consultants and GPs which it supplied to an intermediary agency and which in turn supplied the doctors to various clients (usually NHS trusts). Both the FTT and UT had decided in HMRC’s favour that Mainpay’s services did not fall within the scope of the exemption for medical care. The taxpayer appealed to the CA.
The CA was satisfied that there was nothing conceptually wrong with the approach of the FTT in asking whether there was a supply of staff or a supply of medical services. Case law made clear that there was a...
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Umbrella company did not supply exempt medical care
In Mainpay Ltd v HMRC[2022] EWCA Civ 1620 (9 December 2022) the Court of Appeal (CA) held that supplies made by an umbrella company which employed consultants and GPs did not fall within the VAT exemption for medical care and were instead taxable supplies of staff.
Mainpay employed consultants and GPs which it supplied to an intermediary agency and which in turn supplied the doctors to various clients (usually NHS trusts). Both the FTT and UT had decided in HMRC’s favour that Mainpay’s services did not fall within the scope of the exemption for medical care. The taxpayer appealed to the CA.
The CA was satisfied that there was nothing conceptually wrong with the approach of the FTT in asking whether there was a supply of staff or a supply of medical services. Case law made clear that there was a...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")