VQOTW: FRS & Partial Exemption

My client has a limited company clinic offering cosmetic beauty treatments. Most of the treatments are subject to VAT, but some are exempt where carried out by nurses on patients who have been referred to the clinic by their doctor as part of a programme of medical treatment. The company is VAT registered and uses the Flat Rate Scheme – with a flat rate of 12%. They have recently purchased a new piece of medical equipment, costing £4,500 including VAT, which will be used to carry out both taxable and exempt treatments. We are having a debate within our practice about whether VAT can be recovered as the purchase of “capital expenditure goods” over £2000 when those goods are going to be used to make exempt as well as taxable supplies. Can the input tax be recovered in full?

I can see why this is causing a debate, it is counter-intuitive to consider that a partially exempt business can recover VAT in full on the purchase of an asset used by the business as a whole. In this case however, the business is entitled to recover the VAT on the purchase of the asset. The rationale behind this is that the purpose of the Flat Rate Scheme is to simplify record-keeping for the VAT registered business. There is no requirement under the scheme to distinguish between taxable supplies (at standard, reduced or zero rate of VAT) or exempt supplies: the VAT-inclusive value of all taxable and exempt supplies is included within the turnover to which the flat rate percentage is applied. On this basis, it reasonably follows that where input tax is recoverable no apportionment is required to be made.

This aspect is covered in the Flat Rate Scheme VAT Notice 733, in section 15.8 which looks at both exempt and non-business use of capital expenditure goods

15.8 Apportionments for private use

To help simplify the Flat Rate Scheme, where VAT on capital expenditure goods is reclaimable, the intended use of those items is treated as wholly for taxable supplies.

This means that you do not apportion input tax to cover any planned private or exempt use of the goods. This is different to the normal VAT rules.

For example, if employees are allowed free use of the company van at weekends to move goods, or a business video camera is used free by a friend of the proprietor to video a family wedding, then there is no restriction of input tax or payment of output tax under the Flat Rate Scheme.

A further point to note is that where input tax is claimed on capital expenditure goods, if/when they are sold out of the business, output tax must be accounted for at the appropriate VAT rate for the sale (not at the flat rate).


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Hilary has worked in VAT since 1997, including five years with HMRC as an Assurance and Enquiries Officer. She spent eight years as a VAT manager, initially with a mid-tier accountancy firm, followed by six years with PricewaterhouseCoopers.

She has both advisory and compliance experience, working with a wide variety of clients ranging from small owner-managed businesses, to not-for-profit organisations and large multinational corporations, on the full range of VAT technical matters.

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