Your question comes at a very opportune time, as just last week HMRC issued Revenue and Customs Brief 11 (2021): VAT liability of coronavirus (COVID-19) testing services, which provides much anticipated clarification on this matter.
In the Brief HMRC confirm that “the service of COVID-19 testing is treated as medical care where it involves administration of the test to the patient and the provision of the results by a medical professional (including where such activity is supervised by a medical professional).
In line with the normal VAT rules that apply to such care, it can only be exempted where it is:
- carried out and supplied by a relevant health professional within the meaning of items 1, 2, 2A or 3 of Group 7 of Schedule 9 of the VAT Act 1994. Health professionals are listed in paragraph 2.1 of VAT Notice 701/57
- supplied by a non-registered person, but the services are wholly performed by a relevant health professional — the exemption does not apply where the health professional is a dental technician
- carried out by a non-registered person acting under the supervision of a relevant health professional — the exemption does not apply where the health professional is a pharmacist, pharmacy technician or dental technician
- supplied by a hospital or state regulated institution — in this case the exemption also covers the supply of any goods in connection with the supply — Check VAT Notice 701/31 for more information.”
On this basis, the service of providing the PCR testing will be exempt provides the persons actually analysing the test results is a registered health professional, or non-registered person supervised by a relevant health professional other than a pharmacist, pharmacy technician or dental technician.
The sales of the self-administered Covid test kits, such as the lateral flow kits which produce an immediate result, and where there is no involvement of a registered health professional, are standard rated supplies of goods.
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