Information on the number of subsidiary companies set up by National Health Service trusts is not collected centrally.
No specific VAT guidance has been issued by the Department in relation to the setting up of wholly owned subsidiary companies by NHS trusts. These companies are subject to normal VAT rules and as such no specific guidance is required. The tax affairs of subsidiary companies set up by NHS trusts will ultimately be an issue for the companies themselves to resolve with HM Revenue and Customs.
The Department’s Finance Director, Chris Young, wrote to NHS trust and foundation trust Finance Directors on 28 September 2017 to clarify the Department’s view on the use of tax advisors, with particular reference to tax avoidance. It should be noted that this letter was not issued with direct reference to any specific tax arrangements being entered into by the NHS.