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Is it a composite charge or each service is priced   for the room rent. This would fall under rental of
           separately?                                          premises and not healthcare.
         - A patient with burns is treated in two stages –      - If the diagnostic tests are outsourced – is the
        preventive and cosmetic                                 diagnostic center directly charging the patient
                                                                or is there a business arrangement between the
           Where does preventive end and cosmetic start?
                                                                health service provider and the labs. Again this
           Is it integral to the wellbeing and preventive in    would be treated as a business arrangement.
           nature?
                                                                - For grey areas while carrying out a treatment,
           What if the cosmetic surgeon came from another       who is making the decisions, and is there a policy
           hospital?                                            of review ad approvals to ensure consistency.

           What about the room charge due to the extend  The above are a few guidelines which makes the
           stay?                                              engagement a bit complex and as professionals we
                                                              need to understand the business model and ensure
           What if there is a time gap between the two        that they are compliant. Ideally, it is always good to
           procedures?                                        break up each part of the business transaction and

         While providing our services regarding VAT, whether   look at them independently as only the provision of
        it is advisory or compliance, it is important that as   preventive health care for the wellbeing.
        the experts we follow the following steps diligently.  Let’s not make the mistake of just assuming that
           - Check to see the tax codes that are applied to   health care services are all zero rated.
           the treatment types to ensure only the preventive
           basic health care treatments for the wellbeing
           are being treated as zero rated and the rest our
           standard rated.
           - The relationships the doctors have with the
           service provider – employee, visiting specialist
           and the reimbursement and sharing of the fees.
           These should not be zero rated

           -The treatment rooms and their usage, for
           example, are the visiting doctors paying a charge                         CA Sanjay Khetrapal



         Disclaimer:
         This article and/or write ups and/or any of its content shall not be treated as opinion and/or advice in any circumstances of the author(s) and/ or the Chapter. Reader’s to apply their best
        judgement in the best interest of their requirement and should seek a formal opinion on any issue.


              The Institute of Chartered Accountants of India (Dubai) Chapter NPIO           TAX JOURNAL 2020    71
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