In HMRC v Jigsaw Medical Services [2018] UKUT 222 (17 July 2018) the UT adopted a narrow interpretation of the circumstances in which zero-rating may apply to the supply of ambulance services.
Jigsaw provided ambulance services. These services are usually exempt under VATA 194 Sch 9 group 7 item 11 as ‘transport services for sick or injured persons in vehicles specially designed for that purpose’. It was accepted that patient transport services are both exempt and zero-rated and that zero-rating takes precedence under VATA 1994 s 30.
The issue was whether the same applied to emergency services. This depended on the interpretation of VATA 1994 Sch 8 Item 4 note 4D. The UT considered that note 4D required consideration ‘of what might be achieved in terms of passenger capacity were the features enabling a wheelchair safely to be carried to be removed’. In the UT’s view this...
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