A number of recent Tribunal cases has shone the spotlight on businesses who have been incorrectly treating supplies of cosmetic treatments as being VAT exempt.

Generally, only those services which are concerned with ‘…..the protection, maintenance or restoration of the health of the person concerned’ when undertaken by a properly registered health professional are capable of qualifying for VAT exemption. 

In the case of dental practices, the following services will typically be exempt from VAT when provided as part of a healthcare programme:

• Dental care and treatment
• Drugs or appliances provided in the course of dental care and treatment
• Dental prostheses

However, those services which are undertaken outside of healthcare and purely for aesthetic reasons such as:

• Teeth whitening
• The fitting of veneers
• Teeth realignment
• Anti-wrinkle injections
• Other treatments to improve the appearance of skin

The income from these services will be subject to VAT at the standard-rate and, for any unregistered practices, must be included within turnover when assessing whether the VAT registration threshold has been exceeded.

Due to recent successes at Tribunal, it is anticipated HMRC will target businesses offering cosmetic treatments. Their focus will not only be on those businesses which are currently VAT registered, but also those who are unregistered but trade above the VAT registration threshold.  In addition to undeclared VAT, affected businesses may also be liable for penalties and interest.

Get in touch

Our VAT team can assist you to check the VAT position of your business and handle interactions with HMRC, if required. For more information on how your business may be impacted, please do not hesitate to get in touch with our specialist VAT team or your usual contact at Johnston Carmichael.