RCB/3/19 VAT—zero-rating of transport of disabled passengers
Revenue & Customs Brief, Issue 3. 14 June 2019
To clarify that HMRC's policy on the scope of the VAT zero rate for transport services has not changed following the Upper Tribunal decision in Jigsaw Medical Services Limited  UKUT 222 (TC).
Suppliers that provide transport services in emergency vehicles (ambulances) or in passenger vehicles (such as, out-patient mini-buses) including those adapted for the carriage of one or more wheelchairs.
The Jigsaw case considered whether transport in certain types of 'blue light' emergency ambulances was zero rated for VAT. The Upper Tribunal decided that it was not zero rated.
The decision at paragraph 2(2) states it was 'common ground' that 'patient transport ambulance services are both exempt and zero-rated'. This has prompted some transport providers to seek clarification of HMRC's policy. This comment needs to be read in the context of the rest of the decision and the legal tests. It was not referring to all patient transport ambulance services.
The supply of