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Commentary

V2.189Y Group VAT registration—conditions

Part V2 Registration – deregistration

V2.189Y Group VAT registration—conditions

This paragraph examines the conditions that must be met in order for a person to qualify for VAT grouping.

In broad terms, two or more companies may be treated as members of a group provided they1:

  1. Ìý

    •ÌýÌýÌýÌý satisfy the establishment condition

  2. Ìý

    •ÌýÌýÌýÌý satisfy the control condition

  3. Ìý

    •ÌýÌýÌýÌý are not caught by anti-avoidance provisions

  4. Ìý

    •ÌýÌýÌýÌý are not tour operators (subject to certain conditions)2

In some circumstances certain non-corporate persons may also qualify to be treated as members of a VAT group3.

The conditions outlined above and the circumstances in which non-corporate persons may also be treated as members of a UK VAT group are examined in detail below.

Establishment condition—VAT grouping

A company is eligible to be treated as a member of a group if either it4:

  1. Ìý

    •ÌýÌýÌýÌý is established in the UK

  2. Ìý

    •ÌýÌýÌýÌý has a fixed establishment in the UK

Establishments and fixed establishments

HMRC considers5

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