HMRC argue that a supply of ‘health professionals’, nursing auxiliaries, care assistants and support workers through an ‘employment business’ is a standard-rated supply of staff (rather than being an exempt supply of health or welfare) if the management and direction of the individual is the responsibility of the hiring organisation (HMRC Brief 12/2010 (18 March 2010); Notice 701/57 (Health professionals); Notice 700/34 (Staff)). The third party is responsible for providing healthcare to the final patient, rather than the business supplying the staff.

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