Spectrum Community Health CIC v HMRC

In Spectrum Community Health CIC v HMRC [2022] UKFTT 237 (TC) (1 August 2022) the FTT held that the taxpayer's supplies of various healthcare services to prisoners in England were one single composite supply that was exempt rather than multiple separate supplies with differing VAT status as the taxpayer contended. Spectrum had been engaged to deliver an integrated primary healthcare service equivalent to that provided by the NHS in the general community. This was a single supply that it would be artificial to split.

NHS England (NHSE) engaged Spectrum Community Health CIC (S) to deliver primary healthcare at various prisons. S agreed to provide a range of services including nurses GPs pharmacies mental and sexual health services optometry dentistry and physiotherapy. 

S was of the view that each of these services was...