Supply of ambulance services

Jigsaw Medical Services Ltd

Whether the supply of ambulance services to NHS is exempt care or zero rated passenger transport.

This case concerns VAT recovery on the purchase of ambulances. The taxpayer argued that it was making zero rated supplies of transport to the NHS. HMRC considered the supplies were exempt under VATA 1994 Schedule 9, Group 7, Item 11 - transport services for sick or injured persons in vehicles specially designed for that purpose.

The original FTT found the supplies fell under both and allowed the taxpayer’s appeal as zero rating trumps exemption if both can apply. This was overturned by the UT, which found the FTT had erred in its interpretation of the relevant zero rating provisions.