Measure
The government has announced its intention to repeal Item 5 of Group 7 of Schedule 9 to the VAT Act 1994. This provision currently exempts the supply of “a deputy for a person registered in the register of medical practitioners or the register of medical practitioners with limited registration” and was held in Isle of Wight NHS Trust [2025] UKFTT 1114 to apply to supplies of locum doctors.
The government has stated that deputising services will remain within the scope of the medical exemption, where those services consist primarily of providing medical care.
Suppliers and recipients of the services of locum doctors and other deputies for registered doctors, including most NHS Trusts.
From 1 May 2027.
By way of background, HMRC have decided not to appeal Isle of Wight NHS Trust and have released two Revenue and Customs Briefs, most recently in RCB 6 (2026), published on 17 July 2026. This RCB noted an expectation that suppliers would make claims for overpaid output tax, which would be reviewed on a case-by-case basis.
This change will likely create complexity for suppliers of locum doctors and other medical deputies, particularly where the 1 May 2027 implementation date spans a partial exemption year.