In HMRC v DPAS [2015] UKUT 585 (5 November 2015) the UT found that DPAS was only providing services to patients who had signed a DPAS Authorisation Form.
DPAS provided practice branded dental plans under arrangements which had been changed in January 2012. Dental plans were arrangements between a dentist and his or her patient under which the dentist agreed to provide a certain level of dental care for a monthly fee. The plan also included insurance and payment administration services provided by DPAS. The issue was whether DPAS provided services to patients and if so whether these services were exempt as ‘transactions concerning payments and transfers’ (Principal VAT Directive article 131(1)(d)).
The UT considered that the effect of the language in the DPAS Authorisation Form signed by some patients on the change of arrangements was that the monthly payments included in...
