In HMRC v Jigsaw Medical Services Limited [2018] UKUT 222, the Upper Tribunal (UT), overturned the First-Tier Tribunal (FTT), finding that emergency ambulance services cannot be zero-rated and were exempt.

Where services fall within both the exempt schedule and zero-rated schedule, the zero rated schedule will take precedence.

Jigsaw argued that the emergency ambulance services, where the vechicle is adapted for stretchers and other equipment should fall within the zero-rating provision and this takes precedence over the exemption.

The FTT, in a short decision, determined that zero-rating applied and took precedence:

The UT overturned the FTT decision:

The FTT erred in law and HMRC's appeal was allowed. The emergency ambulances did not fall within the zero-rating schedule and those services were only exempt.

External link: HMRC v Jigsaw Medical Services Limited [2018] UKUT 222


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