Usually you do not charge VAT. A freelance nurse with BIG registration or a certified care worker (VIG) who provides care within their own expertise is exempt from VAT, even if the assignment comes through an agency. The exemption only falls away if your work is in fact supplying staff, or if you do work without a therapeutic purpose.
According to the Belastingdienst, whether the exemption applies depends on what your agreement with the client says. That is why it makes sense to read that agreement carefully before you start invoicing.
In short
- The Belastingdienst: if you have a contract for services stating that you do the work under your own responsibility and at your own risk, and the work meets the conditions, you may assume the exemption applies. Assess each assignment separately.
- The KVK puts it more strictly: if you invoice the care institution directly, the exemption applies, if you invoice the agency, you are liable for VAT. That rule is not stated in that way in a Belastingdienst source.
- Employment agencies always charge 21% VAT on care staff, even with BIG registration. If you work as a subcontractor responsible for the content and quality of your work, there is no supply of staff.
In this article
- Is your care as a freelance nurse or certified care worker exempt from VAT?
- Does an agency change anything about the exemption?
- What does the KVK say about invoicing through the agency?
- When is it a supply of staff and therefore taxed?
- And if the agency itself organises the care?
- What does this mean for your invoices and costs?
Is your care as a freelance nurse or certified care worker exempt from VAT?
Yes, if you provide care within your expertise and meet the conditions for your profession. The nurse is a profession under article 3 of the BIG Act (BIG Act, article 3). For such a profession the exemption only applies if you are on the BIG register (Belastingdienst, Professions regulated by the BIG Act).
The certified care worker (VIG) is a profession under article 34 of the BIG Act (Decree on certified care workers in individual healthcare, Bulletin of Acts and Decrees 1999, 463). Article 34 professions have no registration requirement, and you apply the exemption if you meet the other conditions (Belastingdienst, Professions regulated by the BIG Act). The KVK also states that a VIG does not need to register in the BIG register (KVK, Starting as a freelance nurse or care worker, updated 15 September 2026).
If you work as a care assistant without a BIG profession, your work may still be exempt through the client: Wlz care for someone with a Wlz needs assessment, or Wmo support for someone the municipality has found entitled to it (Belastingdienst, Exemption for social support and long-term care). All routes to the exemption are covered in a separate article on VAT in care.
Does an agency change anything about the exemption?
Not automatically. The Belastingdienst writes that a care agreement often involves more parties, such as an agency or a care institution. Whether you as a self-employed person can use the exemption depends on what your agreement with the client says (Belastingdienst, Exemption in healthcare).
If you have a contract for services stating that you carry out the work under your own responsibility and at your own risk, and your work meets the conditions for the exemption, you may assume that the exemption applies. If you have several clients or several agreements with the same client, you assess each assignment separately (Belastingdienst, Exemption in healthcare).
In 2014 the Supreme Court ruled that the services of a self-employed anaesthesia assistant to a hospital are medical care, and therefore exempt, and not a supply of staff (Supreme Court, 13 June 2014, ECLI:NL:HR:2014:1375). The Supreme Court looked at what the parties had agreed.
What does the KVK say about invoicing through the agency?
The KVK gives a simple rule of thumb. If you get the assignment through an agency and send the invoice directly to the care institution, that falls under the exemption. If you carry out the assignment at a care institution under a contract for services and send the invoice to the agency, the KVK says you are liable for VAT (KVK, Starting through a care agency, updated 26 June 2025).
That rule is stricter than what the Belastingdienst writes. The Belastingdienst looks at the content of the agreement, not at the address on the invoice. No Belastingdienst source or ruling confirming the KVK rule in that form has been found. So treat the KVK rule as a warning, not as law.
What the KVK rule does show well: if the agency buys your services and resells them, it becomes harder to show that you provide care yourself under your own responsibility. Invoicing the institution, with the agency only as intermediary, removes that question.
When is it a supply of staff and therefore taxed?
Employment agencies that supply care staff always charge 21% VAT on those services, even if the staff have BIG registration (Belastingdienst, Exemption in healthcare). Making staff available is in principle taxed (Decree on turnover tax and making staff available, version 15 June 2024, section 1).
According to the decree there is no supply of staff but subcontracting if four conditions are met (Decree on making staff available, section 3.5):
- there is a contract for services in which you are responsible for the result, the content and the quality of your work
- the work is described in that agreement so that it is clear what you do, detail is not required
- the agreement shows there is no employment or agency contract, or any other relationship in which you are subordinate
- and you also work that way in practice
These conditions can also be met if final responsibility for the quality of care remains with the client (Decree on making staff available, section 3.5). The fact that the institution has final responsibility and you follow the care plan does not by itself make your work a supply of staff.
Between two providers of Wmo care, and between two providers of youth care, supplying staff has been exempt under conditions since 1 January 2021. The staff must then be used for work that falls under the same exemption (Decree on making staff available, section 4.3).
And if the agency itself organises the care?
Then the agency itself may provide care. In 2023 the Court of Appeal in The Hague ruled on a regional branch of a home care organisation working with freelancers. According to the court the work was not merely intermediation, because the branch also determined the duration and nature of the care, coordinated the process, reported and monitored quality. The branch fell under the exemption for Wlz and Wmo care and received € 95,997 of VAT back (Court of Appeal The Hague, 30 March 2023, ECLI:NL:GHDHA:2023:777).
Such an agency may also be a care provider itself under the Wtza. According to the CIBG, an agency that agrees with a personal budget holder or health insurer to provide care, arranges replacement during illness and makes agreements on the content of care is a care provider and needs a licence (CIBG, Questions about the licensing requirement).
What does this mean for your invoices and costs?
If your care is exempt, you put no VAT on the invoice and you may not deduct the VAT on your costs. If you also do taxed work, you may deduct the VAT on costs for that taxed work (Belastingdienst, What should you do if you supply exempt goods or services?). If the agency charges you VAT on its intermediary fee, that VAT is therefore a cost for your exempt care.
About two weeks after registering with the KVK, you receive a letter from the Belastingdienst stating whether you must file returns or are exempt. It is your own responsibility to check that this is correct (KVK, Starting through a care agency). If you later also do taxed work, such as examinations for a third party or organisational advice, you must report this and start filing returns (Belastingdienst, Exemption in healthcare). How that return works is explained in a separate article (Filing a VAT return).
Also pay attention to your entrepreneur status for income tax. The KVK points out that the Belastingdienst requires several clients as a condition for tax benefits such as the self-employed deduction, and that you should watch this when working through one agency (KVK, Starting through a care agency).
The number of self-employed workers in long-term care has grown in recent years, and research shows that their position varies widely. Interviews with 23 self-employed nurses and nursing aides showed that for some of them entrepreneurship brought financial insecurity (Duijs et al., 2022). Research on care through intermediaries showed that these intermediaries play a central role in contracts and recruitment, and that rules can develop blind spots as a result (Hernandez, Bartošová & Van Hooren, 2026). A clear agreement therefore protects more than your VAT position.
Sources
- Belastingdienst, Exemption in healthcare (in Dutch), accessed 1 November 2026. belastingdienst.nl
- Belastingdienst, Professions regulated by the BIG Act (in Dutch), accessed 1 November 2026. belastingdienst.nl
- Belastingdienst, Exemption for social support and long-term care (in Dutch), accessed 1 November 2026. belastingdienst.nl
- Belastingdienst, What should you do if you supply exempt goods or services? (in Dutch), accessed 1 November 2026. belastingdienst.nl
- Individual Healthcare Professions Act (Wet BIG), article 3, version 5 July 2025 (in Dutch). wetten.overheid.nl
- Decree on certified care workers in individual healthcare, Bulletin of Acts and Decrees 1999, 463 (in Dutch). officielebekendmakingen.nl
- Decree on turnover tax, making staff available, version 15 June 2024 (in Dutch). wetten.overheid.nl
- KVK, Starting through a care agency, updated 26 June 2025 (in Dutch). kvk.nl
- KVK, Starting as a freelance nurse or care worker, updated 15 September 2026 (in Dutch). kvk.nl
- Supreme Court of the Netherlands, 13 June 2014, ECLI:NL:HR:2014:1375 (in Dutch). uitspraken.rechtspraak.nl
- Court of Appeal The Hague, 30 March 2023, ECLI:NL:GHDHA:2023:777 (in Dutch). uitspraken.rechtspraak.nl
- CIBG, Questions about the licensing requirement (in Dutch), accessed 1 November 2026. toetredingzorgaanbieders.nl
- Duijs, S.E., Abma, T., Plak, O. et al. (2022). Squeezed out: experienced precariousness of self-employed care workers in residential long-term care, from an intersectional perspective. Journal of Advanced Nursing, 79(5), 1799-1814. doi.org
- Hernandez, S., Bartošová, K. & Van Hooren, F. (2026). The limits of state control in regulating live-in care work in the Netherlands. Social Inclusion, 14. doi.org