Is a doctor's telemedicine consultation fee exempt from VAT?

No BIR issuance specifically addresses telemedicine, but the VAT exemption under NIRC Section 109(1)(G) for medical services rendered by a licensed, PRC-registered physician turns on who performs the service and what kind of service it is — professional medical diagnosis and treatment — not on the medium through which it's delivered. On that reasoning, a doctor's own professional fee for a video or phone consultation should qualify for the same exemption as an in-person visit, though this is an extension of the general rule rather than a telemedicine-specific ruling.

Does the VAT exemption depend on the doctor's income level?

The exemption for a medical professional's own service fee under Section 109(1)(G) is not conditioned on an income threshold the way the general VAT registration threshold is for most other businesses — it exempts the professional service itself. A doctor's income from other, non-exempt activities (such as selling medicine or medical supplies) is evaluated separately under the ordinary VAT rules.

Is the telehealth platform's own service fee also VAT-exempt?

No. A telehealth platform that facilitates bookings, hosts the video call, and takes a service fee or commission from the doctor's fee is providing a technology/facilitation service, not a medical service — that platform fee is a separate, ordinary VATable (or percentage-tax, if below the VAT threshold) transaction, distinct from the doctor's own exempt professional fee.

Does a corporate client have to withhold tax when paying a doctor through a telehealth platform?

Generally yes, under the same expanded withholding tax rules that apply to any professional fee paid to a licensed individual practitioner — the fact that payment is routed through a platform rather than handed to the doctor directly doesn't remove the corporate payor's withholding obligation under RR No. 2-98 as amended.

Where should a telehealth doctor confirm this if they want certainty?

Because no BIR revenue regulation or memorandum circular names telemedicine specifically, a physician or clinic billing significant telehealth volume should consider requesting a BIR ruling confirming the exemption applies to their specific service model, rather than relying solely on the general reasoning described here.

Is a Telemedicine or Telehealth Consultation VAT-Exempt the Same Way an In-Person Doctor's Visit Is?

A licensed physician’s professional fee for a telemedicine or telehealth consultation should qualify for the same VAT exemption that applies to an in-person visit — because the exemption under the National Internal Revenue Code (NIRC) turns on who is providing the service and what kind of service it is, not on whether the patient and doctor are in the same room. No BIR revenue regulation or memorandum circular specifically addresses telemedicine, so this conclusion follows by applying the existing medical-services exemption to a new delivery channel, rather than from a telehealth-specific ruling — a distinction clinics and platforms billing telehealth fees should keep in mind.

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What the VAT exemption for medical services actually covers #

NIRC Section 109(1)(G) exempts from VAT the services rendered by a long list of licensed professionals, and medical services are among them — but the exemption attaches to the professional performing the service, not to a particular setting or format. Revenue Regulations No. 7-2004, which implemented this exemption, covers medical, dental, and veterinary services rendered by professionals, consistent with the broader category of VAT-exempt professional services the regulation addresses:

Services subject to percentage tax under Title V of the Tax Code, as well as services rendered by doctors of medicine, lawyers, certified public accountants, and other professionals duly registered with the Professional Regulation Commission, are exempt from VAT.

Because the exemption is framed around who is rendering the service (a PRC-licensed professional) and the nature of the service (medical diagnosis, consultation, or treatment), nothing in the regulation’s text ties the exemption to the service being delivered in a specific physical location. A video consultation in which a licensed physician diagnoses a patient and recommends treatment is, in substance, the same professional act as an in-person consultation — just conducted over a different medium.

Why the platform’s own fee is a different story #

The moment a telehealth platform charges its own separate fee — a booking fee, a subscription, or a percentage cut of the consultation fee — that platform fee is not itself a medical service, and the exemption doesn’t follow it over. A telehealth platform (the app or website connecting patients to doctors, hosting the video call, and processing payment) is providing a technology and facilitation service. That service is ordinarily VATable if the platform operator exceeds the ₱3,000,000 VAT threshold, or subject to percentage tax under NIRC Section 116 if it doesn’t — the same general rule that applies to any digital marketplace or booking platform, unrelated to the medical-services exemption the doctor personally enjoys.

Who charges the fee	What’s being paid for	VAT treatment
The doctor (consultation fee)	Medical diagnosis/treatment, delivered via telehealth	Exempt under Section 109(1)(G), by extension of the in-person rule
The telehealth platform (platform/booking fee)	Technology facilitation, not a medical service	Taxable — VAT if above threshold, percentage tax if below

Does withholding tax still apply when a corporate client pays? #

Yes — a corporate client that pays a doctor’s telehealth consultation fee, whether directly or routed through a platform, is still the withholding agent responsible for expanded withholding tax on that professional fee, the same as it would be for an in-person visit. An employer that contracts a telehealth provider for occupational health consultations, or an HMO that reimburses a platform for member consultations, applies the same professional-fee withholding mechanics described in this site’s consolidated EWT rates reference — the payment channel doesn’t change who owes the withholding obligation, only how the payment physically moves.

Worked example: a corporate wellness telehealth contract #

A company contracts a telehealth platform so employees can book video consultations with a roster of independent physicians. The platform bills the company ₱150,000 for the month: ₱120,000 of that is passed through to the doctors as their consultation fees, and ₱30,000 is the platform’s own facilitation fee.

The ₱120,000 in doctors’ fees: VAT-exempt under Section 109(1)(G), by the same reasoning that exempts an in-person consultation fee — subject to the company confirming each doctor is PRC-licensed and the fee is genuinely their own professional charge, and subject to the company still withholding the applicable professional-fee EWT rate before remitting payment to each doctor.
The ₱30,000 platform fee: Not exempt — this is the platform’s own taxable service fee, subject to VAT if the platform is VAT-registered (which a platform processing this volume typically would be), with the company able to claim input VAT on that portion if it is VAT-registered itself.

Summary #

A doctor’s telemedicine consultation fee should carry the same VAT exemption as an in-person professional fee under NIRC Section 109(1)(G), because the exemption depends on the professional and the nature of the service, not the delivery channel — but no BIR issuance confirms this for telehealth by name, so it rests on extending the existing rule rather than a direct ruling. A telehealth platform’s own facilitation fee is a separate, taxable service with no claim to the doctor’s exemption, and a corporate payer still has to withhold on the doctor’s professional fee regardless of how the payment is routed. For the underlying withholding mechanics, see this site’s expanded withholding tax rates reference and its guide to BIR Form 2307 for medical practitioners.

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