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V1334-17 31 May 2017 · SG de Impuestos sobre el Consumo Criterion in force
IVA · asistencia sanitaria

VAT exemption for radiological protection services depends on purpose and provider

A taxpayer has queried whether radiological protection services for patients (RPS) in hospitals are exempt from VAT as healthcare services. The DGT indicates that exemption depends on whether the primary purpose is health protection and whether the providers are healthcare professionals.

The question raised

Whether such services are considered hospitalization services or healthcare services exempt from Value Added Tax.

The DGT's ruling

For healthcare services to be exempt, they must meet two requirements: they must aim at the diagnosis, prevention, or treatment of diseases, and they must be provided by medical or healthcare professionals. If a transaction includes several elements, it shall be determined whether they are independent supplies or a single supply based on whether some elements are ancillary to the main service. The DGT indicates that activities such as quality control of equipment might not meet the objective requirement, whereas the design of the appropriate treatment could be included.

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