Cosmetic dentistry and VAT are becoming a hot topic as more dentists move into facial aesthetics and non-surgical treatments like Botox and dermal fillers. While these services can boost revenue, they also bring VAT complications that HMRC is now looking at in more detail. If you’re a dentist offering cosmetic treatments, here’s what you need to know.
Why Cosmetic Dentistry VAT Exemption Matters
Many dentists assume that because they are registered medical professionals, all of their services are VAT exempt. Unfortunately, that’s not always true. Under Item 1, Group 7, Schedule 9 of VATA 1994, VAT exemptions apply only to medical care services that diagnose, treat, or cure disease or ill health. Unlike cosmetic dentistry, facial aesthetics often fall outside this definition.
The Illuminate Case – A Warning Sign For VAT Registration
Illuminate Skin Clinics Ltd offered treatments such as fat freezing, fillers, and facials. HMRC ruled these were not exempt from VAT because they were primarily cosmetic. Illuminate Skin Clinics Ltd appealed to the First-tier Tax Tribunal, but they agreed with HMRC, stating:
- Cosmetic treatments enhancing the overall appearance of the face, rather than teeth and smile, even by a qualified doctor (or dentist), are 20% standard-rated for VAT.
- Feeling unhappy with your appearance is not a medical condition.
- Consultation notes must show a genuine diagnosis of a health disorder, not just aesthetic concerns.
Illuminate Skin Clinics Ltd then appealed to the Upper Tax Tribunal, and they also confirmed that the principal purpose of the treatment matters. If it’s cosmetic for the overall appearance of the face, VAT applies.
Dentists and Botox – What HMRC Looks At
If you’re injecting Botox other than as part of your dental work, HMRC will consider:
- Purpose of treatment – Is it dental or purely cosmetic?
- Documentation – Are you recording a proper diagnosis or just noting wrinkles?
- Customer perspective – Is this a beauty service or medical care?
VAT Registration Threshold
Even if you’re starting small, watch your turnover. Once your taxable sales for Botox and other facial aesthetic treatments exceed £90,000 in any rolling 12 months, you must register for VAT.
All of your income from dentistry will remain exempt from VAT, even when you are registered for VAT.
Practical Tips for Dentists
- Monitor your sales – Keep under the £90,000 threshold where possible
- Don’t assume exemption – Facial aesthetics are 20% VAT rate.
- Keep detailed records – If claiming exemption, show a clear dental treatment plan.
- Factor VAT into pricing – Avoid unexpected bills.
- Get advice early – HMRC is actively challenging borderline cases.
Bottom Line
Cosmetic treatments and dentistry VAT rules are strict. Cosmetic treatments marketed for appearance enhancement are almost always subject to VAT. Dentists moving into aesthetics need to plan because HMRC is watching this emerging industry.
