HMRC has now published Revenue and Customs Brief 6 (2026), setting out its position on the issue. HMRC says that supplies of locum doctors may fall within the VAT exemption under Item 5, Group 7, Schedule 9, Value Added Tax Act 1994 for “the provision of a deputy for a person registered in the register of medical practitioners” where the locum doctors: 

• are registered with the GMC; and 
• perform medical services in that professional capacity.  

This includes where locum doctors are supplied via an employment business.  

HMRC says that the VAT exemption does not apply to the supply of other GMC registered healthcare professionals, such as allied health professionals or anaesthesia and physician associates.  

Revenue and Customs Brief 6 (2026) explains how businesses that believe they have overdeclared output tax can claim a refund. HMRC says that it will review claims on a “case-by-case basis” and that “will include consideration of unjust enrichment, partial exemption and whether overdeclared VAT has been correctly accounted for across the supply chain”.