HM Revenue & Customs


by Berthold Bauer on March 5, 2024

HM Revenue & Customs suffer historic defeat in long-running legal case over the VAT liability of car parking at NHS Trust operated car parks.

The Court of Appeal have recently ruled in favour of Northumbria NHS Foundation Trust regarding their case against car parking income being subject to VAT, where an NHS Trust operates its own car parking facilities. HMRCs longstanding view has been that VAT is chargeable at the standard rate on car parking charges, however this ruling determines this is not the case.

As this is a recent ruling, we are awaiting the release of the full case and any HMRC comment or Revenue & Customs’ brief, which we will analyse and digest. In the meantime, we wanted to make you aware that if your Trust operates its own car park(s), and has been receiving taxable income for these, a reconciliation exercise will likely be needed in due course.


What do I need to do?

If you are a Trust who ‘stood behind’ the appellant on this case, or have engaged another advisor directly on this matter, please let us know.

Alternatively, if you are unaware of this case or would like to find out more, we will be covering the matter in our upcoming NHS Partial Exemption Statement of Practice webinar, being held at 10am on Wednesday 6th March. If you would like to attend, please register via our website.

As soon as we have digested the full case, and HMRC have declared the necessary actions retrospectively, and moving forward, we will get back in touch to discuss what impact there may be on your Trust.

If you have any queries at all in the meantime, please do not hesitate to reach out to your main BB VAT consultant, or alternatively you can email

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