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V2636-19 26 September 2019 · SG de Impuestos sobre el Consumo Criterion in force
IVA · exención sanitaria

Healthcare services provided by a mediation platform are VAT exempt if acting in their own name

A company that connects patients with doctors via an application has requested clarification on whether healthcare services are VAT exempt and how its mediation services are taxed. The DGT ruled that medical assistance is exempt and that, if the company acts in its own name, it is considered to be both receiving and providing the healthcare services itself.

The question raised

Taxation of the services provided by the hospital to the applicant, and by the latter to its clients. Application of the healthcare exemption under Article 20-One-3º.

The DGT's ruling

Medical, surgical, and healthcare assistance services for diagnosis, prevention, or treatment are exempt from VAT if provided by medical or healthcare professionals, even if they invoice through a commercial company. If the mediation entity acts in its own name, it is understood that it receives and provides the healthcare services itself, so these shall also be exempt. However, marketing services provided by commercial agents are subject to the general rate of 21%.

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