Teeth on edge

The taxpayer DPAS designed and implemented dental plans under which the private patients of dentists who were registered with DPAS could spread the cost of basic dental healthcare throughout the year.

The plans administered by the taxpayer were branded in the name of the dentists’ practices. Each month the taxpayer accounted to the dentists for the aggregate amount payable to them for all of their patients who had paid the monthly fee less a sum retained by DPAS as a charge for its services. The taxpayer managed the administration finance and insurance side of the dental plans.

HMRC accepted that DPAS made exempt supplies of “transactions concerning ... payments transfers” within the Principal VAT Directive.

In 2008 the taxpayer introduced a £10 registration fee to recover the cost of registering a patient on a dental plan directly from the patient.

In October 2010 ...