VAT Status – CT Scans

VAT Status – CT Scans

CTM represented a group of consultant doctors, including cardiologists and radiologists, who offered CT scanning services to patients. HMRC had raised VAT assessments on the basis that these services were standard-rated.

HMRC’s Position

HMRC’s position was that CT scans, taken in isolation, do not constitute medical care. On this basis, HMRC argued that the scanning services were standard-rated supplies and that VAT was chargeable.

CTM’s Argument

CTM argued that the consultants were not simply providing scans in isolation. The consultants provided a full diagnostic service that included:

• Clinical assessment of the patient
• The CT scan itself
• Interpretation and analysis of the scan results
• A full diagnosis
• A treatment plan as part of ongoing healthcare delivery

CTM’s case was that the supply, properly characterised, was a supply of medical care by qualified medical professionals, which is exempt from VAT.

The Outcome

HMRC withdrew the VAT assessments within 4 weeks of CTM submitting the appeal, confirming the VAT-exempt status of the scanning services.

This case demonstrates the importance of properly characterising the nature of a supply for VAT purposes and the value of expert representation in challenging HMRC’s assumptions.