In Mainpay Ltd v HMRC [2021] UKUT270, the Upper Tribunal found that the taxpayer was supplying staff not medical care. The supplies were not exempt and were taxable at the standard rate.

Mainpay Ltd (Mainpay) was an umbrella company providing temporary medical staff. 

The UT dismissed the appeal.

Useful guides on this topic

Health and welfare: VAT
Reduced rating, zero-rating and VAT exemption can apply to various services relating to medical care, health and welfare.

Supply of GPs was a service and VAT exemption upheld
In Archus Trading Limited v HMRC [2020] TC07557, the First Tier Tribunal (FTT) concluded that the supply of GPs were supplies of services, not staff, and qualified for VAT exemption.

External link

Mainpay Ltd v HMRC [2021] UKUT270

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