HMRC’s new approach to the cosmetic medical sector

HMRC has recently formed a specialist team to target the rapidly growing cosmetic medical sector. The focus of attention is whether treatments such as Botox fillers or facial chemical peels qualify for medical exemption from VAT.

To put it simply HMRC’s position is that the treatments should be treated as standard rated. This has been supported by a recent decision at the First-tier Tribunal (FTT) involving Illuminate Skin Clinics Ltd (TC8846).

Illuminate had made a claim for VAT credit in relation to the period ending December 2016 which HMRC had denied on the grounds that the supplies made during the period were not exempt from VAT.

In a complex ruling the tribunal considered written and oral evidence from Dr Sophie Shotter the director of Illuminate and reviewed a bundle of documents totalling 1 241 pages.

The decision inevitably reflected on a number...