Your dietetic consultations are VAT exempt. A meal plan sold as a standalone product probably is not, it counts towards the VAT registration threshold, and if your website emails it automatically you may owe VAT in the customer's EU country from the very first sale.
That last point has no threshold and no grace period. It is the reason this article exists, because the generic guides to selling digital products never mention healthcare exemption, and the dietitian business content never mentions VAT.
Why are my consultations exempt in the first place?
Because of who you are, not what you do.
VAT Notice 701/57 lists the health professionals whose services are exempt, and dietitians are on it by virtue of HCPC registration. Section 2.3 sets the second condition: the primary purpose of the service must be the protection, maintenance or restoration of the health of the person concerned.
So a dietetic consultation with an identified patient, addressing their health, is exempt. Our discipline-by-discipline VAT guide covers the full list and where the boundaries sit.
The question is whether a meal plan travels with that exemption. Often it does not.
When does a meal plan stop being part of the treatment?
Section 3.1 of the same notice draws the line, and the wording is worth reading carefully. Charges for items administered or applied to your patient in the course of the treatment are exempt along with the treatment. But items that are separable from the treatment are not exempt, and will usually be standard-rated.
Apply that to the two ways dietitians actually sell plans.
A plan written for a named patient after an assessment, as part of their care, is not separable. It is the output of the consultation. Exempt.
A plan sold from your website to somebody you have never assessed, with no clinical relationship and no personalisation, is separable by definition. There is no treatment for it to be part of. Standard-rated at 20%.
The awkward middle is a templated plan sold with a short questionnaire attached. The test is not how much effort went into it. It is whether there is a genuine clinical relationship whose primary purpose is that person's health. If a purchaser could buy it without you ever knowing who they are, you are selling a product.
Why does that matter if I am under the threshold?
Because exempt income and taxable income are counted differently, and this is where dietitians get caught out.
The VAT registration threshold is £90,000 of taxable turnover. Exempt supplies do not count towards it. So a dietitian with £120,000 of purely clinical income never has to register.
Standard-rated meal plan sales do count. Which means a practice with £85,000 of exempt consultations and £8,000 of digital plan sales has crossed the threshold on the £8,000, and must register, even though 91% of the income is exempt.
Once registered you become partly exempt, which brings its own apportionment rules for reclaiming input VAT. That is an accountant conversation, not a blog one, but it is worth knowing it is waiting.
The bit nobody mentions: how you deliver the file changes the rules
This is genuinely strange and it is published in HMRC's own guidance as a table.
For VAT purposes, an electronically supplied service is one delivered with minimal human intervention. HMRC's digital services guidance distinguishes:
| How the PDF reaches the customer | Electronically supplied service? |
|---|---|
| You attach it to an email and send it yourself | No |
| Your system emails it automatically on payment | Yes |
| Customer downloads it automatically from your site | Yes |
Same file. Same price. Same customer. Different VAT regime, decided by whether a human pressed send.
If you are selling only to UK customers this is mostly academic, because the supply is standard-rated either way. It becomes decisive the moment somebody outside the UK buys one.
The EU rule with no threshold
For business to consumer digital services, VAT is due where the customer is, and there is no de minimis. Not a low threshold. None. One sale to a consumer in Ireland creates an obligation from that first transaction.
Your options are to register for Non-Union OSS in a single EU member state and account for all EU sales through it, or to register for VAT in every member state where you have a customer. OSS is the sane route.
Two things soften this in practice.
Manual delivery keeps you out of it. If you personally email the plan, it is not an electronically supplied service, and the place-of-supply rules that trigger the EU obligation do not apply in the same way. That is a real reason a small practice might choose to send plans by hand.
Selling through a third-party platform usually shifts the liability. Where a marketplace handles the sale, the platform is generally treated as making the supply to the customer and takes on the VAT obligation. That is part of what its commission buys.
So what should you actually do?
Five practical decisions.
1. Decide which side of the line each product sits on. Personalised output of a consultation, or standalone product. Write it down, because if HMRC asks, "it felt like part of the service" is not a position.
2. Track plan sales separately from clinical income. You need to know your taxable turnover against £90,000 independently of your exempt income. This is a bookkeeping decision you make once and benefit from forever.
3. Choose your delivery method deliberately. Automatic delivery is better customer experience and worse VAT. Manual delivery is more work and simpler. Both are legitimate; pick knowingly.
4. Decide whether you sell outside the UK at all. Geoblocking non-UK customers is a perfectly reasonable answer for a small practice, and considerably cheaper than OSS registration.
5. Talk to an accountant before you launch, not after. Partial exemption is the kind of thing that is straightforward to set up and painful to unwind.
A note on what this does not change
None of this affects your clinical work. Assessment, diagnosis, planning and review for an actual patient remain exempt, and building a plan for someone you are treating is part of that.
What it affects is the thing many dietitians are advised to build as passive income: the downloadable plan, the recipe pack, the eight-week programme sold to strangers. Those are products. They are taxed like products. And the automated delivery that makes them passive is precisely what pulls them into the stricter regime.
For what it is worth, keeping the two streams cleanly separate in your records is worth doing regardless. Practice systems like Atlacare hold invoices against the patient record with line items, which makes the clinical side easy to evidence; the product sales usually belong in whatever handles your online store, and keeping them apart is the point.
This is general information about VAT treatment, not tax advice. The application of exemption, place of supply and partial exemption rules depends on the specific facts of what you sell and how. Thresholds and guidance change, typically each April. Take advice from an accountant before launching a digital product.
Sources: VAT Notice 701/57, health professionals and pharmaceutical products · The VAT rules if you supply digital services to private consumers · VAT registration thresholds
Related: Is my practice VAT exempt? · What health claims can a dietitian legally make? · Sole trader or limited company?
