VAT for medical professions: exemption and exceptions

Quick answer. Care provided to individuals by regulated medical and paramedical professions is exempt from VAT where it has a therapeutic purpose (article 261, 4, 1° of the French tax code). By contrast, cosmetic medical or surgical procedures with no recognised therapeutic purpose, and non-medical services, are subject to VAT, in principle at the standard rate of 20%.

An aesthetic doctor carries out a dermatology consultation in the morning and a purely cosmetic injection in the afternoon. The first procedure is exempt from VAT, the second may be taxable. This boundary, seemingly subtle, is one of the most frequent sources of reassessment among healthcare professionals. Many practitioners assume their entire activity is outside the scope of VAT, which is not always accurate. Here is how the exemption works, where its limits lie, and how to split your revenue to secure your position.

Article 261, 4, 1° of the French tax code exempts from VAT the care provided to individuals by members of regulated medical and paramedical professions. This notably covers doctors, dental surgeons, midwives, nurses, physiotherapists and, more broadly, practitioners whose practice is regulated.

The central criterion is not status alone, but the purpose of the procedure. The exemption applies to care that pursues a therapeutic aim: to diagnose, treat or cure an illness or a health anomaly. It is this purpose of protecting health that justifies placing the activity outside the scope of VAT.

Concretely, the vast majority of a general practitioner's procedures, of a dentist treating cavities or of a physiotherapist rehabilitating a patient, fall under this exemption. For these practitioners, the question of VAT does not arise day to day, and rightly so. The subject becomes sensitive as soon as part of the activity moves away from therapeutic care.

The main exception concerns cosmetic medical and surgical procedures that do not pursue a therapeutic purpose. The administrative doctrine is now clear: only aesthetic procedures whose therapeutic or diagnostic interest is recognised are exempt.

Two situations allow this therapeutic interest to be recognised. On the one hand, procedures covered by health insurance, where appropriate after prior agreement. On the other hand, procedures whose therapeutic use is recognised by the French National Authority for Health. Failing either, the aesthetic procedure is subject to VAT, in principle at the standard rate of 20%.

The logic is understandable: a reconstruction after an accident or tumour removal pursues a health aim and remains exempt, whereas a purely cosmetic procedure of comfort, with no medical indication, is closer to a taxable service.

We stay cautious on borderline cases. The classification of a given procedure depends on its medical documentation, on any coverage and on the doctrine applicable at the date of the operation. A procedure that looks aesthetic may have a therapeutic justification, and vice versa. This is precisely the ground where a case-by-case analysis is required.

The exemption targets care. It does not cover services that are not care, even when performed by a healthcare professional. Several ancillary activities therefore fall outside the exemption.

• Certain medical expert reports carried out outside a care process, for instance at the request of an insurer or in a judicial context.
• The rental of equipment or premises to colleagues.
• Administrative or commercial services detachable from the act of care.
• The sale of products that is not part of therapeutic care.

These operations fall under the standard regime and may be taxable. This is a point we examine systematically when a practitioner diversifies their income, because these ancillary flows are often recorded with no VAT reflex.

In the healthcare files we handle, the difficulty is rarely the exemption principle, which is robust for classic care. It comes from the grey area: a practitioner developing an aesthetic activity, expert consultations or rental, and who continues to treat the whole as exempt out of habit.

Our recommendation comes down to one idea: reason by nature of revenue, not by profession. A doctor is not exempt as a doctor, they are exempt for their therapeutic care. As soon as an activity moves away from care, the VAT question must be raised, documented and settled. This discipline of splitting avoids most unpleasant surprises.

During an audit, attention focuses on the consistency between the actual activity and the VAT treatment. A practice showing a significant aesthetic activity while declaring all of its revenue as exempt naturally draws scrutiny. The elements observed are concrete: the nature of the procedures, whether or not they are covered by health insurance, the medical documentation justifying a therapeutic purpose, and the respective share of exempt and taxable revenue.

The absence of any split is itself a signal. Accounts that never distinguish procedures by purpose cannot justify the exemption procedure by procedure, which weakens the practitioner's position.

A healthcare professional who carries out taxable procedures may become liable for VAT on that part of the activity alone, while remaining exempt for their therapeutic care. This is what is known as a partial taxable person: part of the activity is within the scope of VAT, the other outside.

Two practical consequences follow.

1. The taxable part may benefit from the VAT base exemption (franchise en base) if the corresponding revenue stays below the applicable threshold. For supplies of services, this threshold is 37,500 euros in 2026. Below it, the practitioner does not charge VAT on their taxable procedures, but must still identify them.
2. Above the threshold, the taxable part shifts to the standard regime: VAT charged at 20%, returns, and a right to deduct on the expenses allocated to that activity. Splitting then becomes a management issue in its own right.

In both cases, the key is the same: accounts that clearly separate exempt revenue from taxable revenue. This is the prerequisite for any securing, and one of the projects we run as part of chartered accountancy in Paris 8 or an outsourced financial management engagement for growing healthcare structures.

Here are the reflexes we recommend to a practitioner whose activity combines care and procedures that may be taxed.

• Map procedures by nature: exempt therapeutic care, aesthetic procedure, expertise, rental, sale.
• Check, for each aesthetic procedure, whether a recognised therapeutic purpose exists (coverage or health authority recognition).
• Set up accounting that distinguishes exempt revenue from taxable revenue.
• Track the cumulative taxable revenue against the base exemption threshold.
• Keep the medical documentation justifying the exemption procedure by procedure.
• Have borderline cases reviewed before fixing the VAT treatment.

A practitioner we support runs a largely predominant general medicine activity, supplemented by a few cosmetic procedures of comfort with no coverage. Until then, all revenue was declared as exempt, by continuity with the main activity.

The analysis led to isolating the non-therapeutic aesthetic share. As long as this revenue stays below the base exemption threshold, the issue is mainly to identify it cleanly and track it. The work involved setting up accounting splits, documenting the nature of each procedure and putting in place a follow-up of the annual cumulative taxable revenue. No figure transfers from one practice to another: the value of the example is the method, not the amount.

Two contextual elements are worth keeping in mind this year. First, the VAT recodification, which changes the numbering of the texts without altering the principle of exemption for care; we explain it in our article on the VAT recodification from the CGI to the CIBS in 2026. Second, the set of key measures on 1 January 2026 for businesses, which may indirectly affect healthcare structures.

We remain cautious on borderline cases and refer to the doctrine applicable at the date of each operation. The classification of a procedure is not presumed: it is documented.