Depending on the circumstances, a provider of healthcare services may be contractually supplying these services to another provider of healthcare services.

For example, a doctor may have contracted with a hospital to provide certain healthcare services from the hospital’s premises. Alternatively, a hospital may have contracted with a laboratory or another hospital for conducting tests or medical procedures for the hospital’s patients.

The question is whether such business-to-business healthcare services are eligible for zero-rating.

A supply of healthcare services may only be zero-rated if the recipient of the supply is also the person who receives the treatment.

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