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Spectrum Community Health CIC v HMRC

In Spectrum Community Health CIC v HMRC [2024] UKUT 162 (TCC) (6 June 2024) the UT upheld the FTT’s decision that the taxpayer's supplies of various healthcare services to prisoners in England were one single composite supply that was exempt from VAT.

The taxpayer (Spectrum) had been engaged to deliver an integrated primary healthcare service in prisons equivalent to that provided by the NHS in the general community. The service was provided under contracts with NHS England (NHSE).  The central issue was whether Spectrum made a single exempt supply of healthcare services or separate supplies of exempt medical care and taxable prescription drugs and contraceptives. The FTT had found there was a single exempt supply of primary healthcare or health and social care.

Spectrum appealed to the UT on four grounds. The first ground related to the order that the FTT had considered matters. The FTT had considered the...

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