Invoicing for doctors — § 39 exemption + taxable services
Doctors and medical practices hold one of the most distinctive positions in the Slovak VAT regime: healthcare services are exempt from VAT without the right to deduct under § 39 of Slovak VAT Act 222/2004 Coll. That means a doctor does not charge VAT on output, but also cannot deduct VAT on inputs (for example, on the purchase of medical equipment). Complications arise when a practice combines exempt supplies (examinations covered by an insurer) with taxable supplies (cosmetic procedures, consulting, lecturing). This guide shows how to invoice correctly in such a mixed practice.
What you wrestle with daily.
Four concrete problems almost everyone in this industry hits. You'll find a fix for each below — or the full set in the 1FAKTURA cloud product.
01
Invoices to health insurers
VšZP, Dôvera, Union — monthly statements with tens to hundreds of patients. Each insurer requires a specific invoice layout per contract. Without the right format, the insurer blocks the payment.
02
Exempt vs taxable in the same practice
Aesthetic medicine and cosmetic procedures are not exempt under § 39 — they carry 23 % VAT. A doctor must record the two types of supplies separately and run pro-rata input-VAT deduction.
03
Private practice + employment
A doctor works at a state hospital and runs a private practice in parallel. The tax logic of the two streams differs — wages carry no VAT, while the private practice can be exempt or taxable.
04
Lecturing and education
A €200 conference lecture is usually an educational service — may be exempt under § 39(1)(j), but informal teaching (a workshop for colleagues) may be taxable. In borderline cases consult a tax advisor.
Which VAT regime applies.
Reference: § 39(1)(b) and (j) of Slovak VAT Act 222/2004 Coll.
Full statute: slov-lex.sk.
For doctors, § 39(1)(b) of the Slovak VAT Act applies: healthcare and related services provided by a healthcare facility or healthcare provider are exempt from VAT without the right to deduct. Practical consequence: the invoice carries 0 % VAT (or no VAT columns at all if you are not a VAT payer), with the note „VAT exemption — § 39(1)(b) of the VAT Act.“ In a mixed practice (exempt + taxable supplies), a VAT-registered doctor must: a) register as a VAT payer, b) keep separate records for the two types of supplies, c) apply a pro-rata input VAT deduction under § 49 of the Slovak VAT Act (the coefficient is calculated annually). Non-healthcare services (cosmetics, wellness massages) are subject to the standard 23 % VAT rate. Education and training may be exempt under § 39(1)(j) if provided by an accredited educational entity.
Monthly invoice for a private practice (non-VAT-payer doctor)
Healthcare services are exempt under § 39(1)(b) — amounts without VAT columns.
| Item | Qty | Price | VAT | Total |
|---|---|---|---|---|
| Preventive check-up — January 2026 (15 patients) | 1 pat | €25.00 | 0 % | €25.00 |
| Consultation and counselling (8 appointments) | 1 h | €40.00 | 0 % | €40.00 |
| Prescription and recipe service | 1 pcs | €5.00 | 0 % | €5.00 |
| Net subtotal | €70.00 | |||
| VAT total | €0.00 | |||
| Amount due | €70.00 | |||
This is an indicative example. The actual line items and totals depend on the specific engagement and supply type.
Built for your industry.
For an instant start, try the free generator — no signup, no waiting for confirmation emails.
Open the generator →1FAKTURA handles three scenarios specific to doctors. First: a „no-VAT invoice“ template (for non-VAT payers) or „classic with 0 % VAT + § 39 clause“ (for VAT payers on exempt supplies). Second: separate records of exempt and taxable supplies — the generator tracks VAT rate per line, and a doctor can compute the pro-rata deduction coefficient yearly from the export. Third: monthly invoices to health insurers — issue the VšZP / Dôvera / Union template once, generate the next ones monthly with the current patient list. UBL 2.1 XML for 2027 — Slovak Act 385/2025 Coll. applies to B2B between VAT payers, so a mixed practice is partly covered too.
Which 1FAKTURA plan to pick.
A solo non-VAT-payer doctor with regular monthly insurer reports is well served by Plan Start (€0 forever). For a smaller practice with a mix of exempt and taxable supplies (aesthetic medicine), we recommend Plan Lite — adding a pro-rata input-VAT account and Pohoda / Money S3 exports. Larger healthcare facilities with an in-house accounting team will fit Plan Pro with REST API integration.
Frequently asked
about invoicing in this industry.
Something missing? Email us — we answer within 4 hours on a business day.
info@1faktura.skI am a doctor — should I register as a VAT payer?+
Aesthetic medicine — VAT yes or no?+
Invoice for VšZP / Dôvera / Union — which format?+
I also give lectures to colleagues — do I charge VAT?+
Is a PDF invoice enough for the insurer, or do I need UBL XML?+
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