In Get a Drip Ltd v HMRC [2025] TC09509, the First Tier Tribunal (FTT) found that supplies of intravenous vitamin drips and vitamin injections fell within the VAT exemption for ‘medical care’.
Get a Drip Ltd (GAD) provided intravenous vitamin drips and vitamin injections from its clinic.
- Following the submission of its first VAT return, which treated GAD’s supplies as zero-rated, HMRC informed GAD that they considered the supplies to be standard-rated.
- After further correspondence between GAD and HMRC, during which the HMRC officer vacillated between considering GAD’s supplies to be both standard-rated and exempt, GAD’s director requested an independent review.
- The independent review found GAD’s supplies to be standard-rated.
- GAD Appealed to the First Tier Tribunal (FTT).
- At the time of appealing, GAD’s director no longer believed that the company’s supplies were zero-rated. Instead, GAD considered that its supplies fell within the Medical care exemption, in VATA 1994, Schedule 9, Group 7.
- This view was on the basis that the supplies were carried out by appropriately qualified medical practitioners, working with their qualifications and were for the protection, maintenance or restoration of the health of the patient involved.
Group 7 of Schedule 9 VATA 1994 exempts the supply of services consisting of the provision of medical care by a person registered or enrolled in:
- The register of medical practitioners.
- The register of qualified nurses, midwives and nursing associates maintained under article 5 of the Nursing and Midwifery Order 2001.
The FTT found that:
- For each of the 12 sample customer cases put before it, a credible, qualified medical expert was able to identify a diagnosed physiological health disorder for which GAD’s practitioners prescribed an appropriate treatment.
- On the balance of probabilities, GAD’s supplies constituted the provision of medical care.
The appeal was allowed.
Useful guides on this topic
Health and welfare: VAT
When do reduced rating, zero-rating and VAT exemption apply to services relating to medical care, health and welfare? What are the rules?
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