The healthcare VAT exemption: when does it apply to you?
Written by Ilias Aarrass7 min read · Published on · Last reviewed on 
In short
The healthcare VAT exemption applies only if you fall under the BIG Act and the treatment is aimed at the patient's health; an assessment for an insurer is taxed at 21 per cent.
- Even without BIG registration the exemption can apply at a demonstrably equivalent quality level.
- Agencies supplying care staff always charge 21 per cent, even for BIG-registered staff.
- If you wrongly charged no VAT for years, the tax authorities can reassess five years back.
- With mixed turnover you deduct only the input VAT attributable to your taxed share.
Working as a freelancer in healthcare, the first question is always: do I charge VAT on my hours? The answer is less clear-cut than it seems. Two nurses doing the same work can get different answers, depending on their registration and who they work for. And getting it wrong is costly, because an assessment runs over several years.
The two conditions
The exemption for medical care of individuals has two tests in practice, and you must meet both.
First, your qualification. The exemption applies to professionals covered by the Individual Healthcare Professions Act: doctors, nurses, physiotherapists, midwives, psychotherapists and several others. If you are not in the BIG register, the main rule is that you charge the regular 21 per cent. There is one opening: if you demonstrably work at a quality level equivalent to that of a BIG-registered professional, the exemption can still apply. That test is strict and the burden of proof is yours.
Second, the purpose of the care. The act must be aimed at the patient's health: examination, diagnosis, treatment or prevention. An assessment for an insurer or a report for an employer serves a different purpose and is therefore taxed, even if you are BIG-registered.
Where it goes wrong in practice
A few situations keep recurring, and that is where wrong assumptions are most often made.
| Situation | VAT |
|---|---|
| BIG-registered, direct patient care | Exempt |
| Assessment or report for insurer or employer | 21% |
| Coaching or counselling without BIG registration | Usually 21% |
| Training or supervision for colleagues | 21% |
| Cosmetic treatment without medical indication | 21% |
| Supplying staff to a care institution | Usually 21% |
Providing care or supplying staff?
This is the trickiest distinction, and it affects nearly every freelancer working through an agency or directly at an institution. Providing care independently, with your own responsibility for the treatment outcome, is exempt care. Effectively making yourself available so the institution deploys you as it sees fit is staff supply, which is taxed.
The actual situation counts, not what the contract says. Who sets your rota, are you responsible for the care plan, and in whose name is the treatment relationship? This borders on false self-employment, since the same facts matter there.
What an exemption costs you
Exempt sounds like an advantage, but it is not always. You charge no VAT to clients, but you also cannot reclaim VAT on your own purchases. Your car, laptop, training and software: that VAT becomes a cost for you. What that means for the rest of your records is covered in bookkeeping for freelancers in healthcare.
If you mainly work for care institutions that are themselves exempt, the exemption does help: they cannot reclaim your VAT, so without it your service would cost them 21 per cent more. More on this in VAT exemption or zero rate.
Mixed work: splitting
Doing both, for instance patient care and training, gives you a mixed practice. You charge VAT on the taxed part and not on the exempt part, and you must split your input VAT: only VAT attributable to your taxed turnover is reclaimable.
Set that up properly from the start with separate ledger accounts. Untangling it afterwards is tedious and nearly always leads to a VAT adjustment.
In doubt? Ask in advance
The healthcare exemption is one of the most litigated topics, precisely because it varies per situation. In a grey area, request a position from the tax authorities in advance rather than guessing.
The reason is simple: having wrongly charged no VAT for years means the tax authorities can go back five years. You usually cannot pass that VAT on to clients afterwards, so it lands entirely on you.
Frequently asked questions
Do I charge VAT as a freelancer in healthcare?
Only if you do not meet the exemption. It applies if you are BIG-registered and the care is aimed at the patient's health. If either is missing, you charge 21 per cent.
Does the exemption apply without BIG registration?
As a main rule, no. Professions outside the Individual Healthcare Professions Act, such as many forms of coaching and counselling, generally fall under the standard 21 per cent rate. Only those who demonstrably work at a quality level equivalent to a BIG-registered professional can still qualify. See bookkeeping for a coach or therapist for the administration that comes with it.
Is an assessment for an insurer exempt?
No. With an assessment or report the purpose is not the patient's health but informing a third party. You charge 21 per cent on that, even when BIG-registered.
What is the difference between providing care and supplying staff?
Providing care independently with your own responsibility for the outcome is exempt care. Making yourself available so the institution deploys you as it wishes is staff supply, usually taxed at 21 per cent.
What if I wrongly charged no VAT?
The tax authorities can then reassess up to five years back. You usually cannot pass that VAT on to clients, so it lands on you. If in doubt, request a position in advance rather than guessing.
Sources
- Exemption for medical professionalsBelastingdienst · belastingdienst.nl
- VAT exemption in healthcareBelastingdienst · belastingdienst.nl
Sources checked on
This article provides general information based on the rules known for 2026 and does not replace personal tax advice. For your specific situation, we're happy to take a look with you.
