In Revenue & Customs Brief 5 (2022), HMRC says that businesses waiting for a response to their VAT grouping application should:
- treat the application as provisionally accepted on the date it was submitted online or the date it should be received by HMRC if submitted by post; and
- account for VAT accordingly.
While waiting to receive a VAT grouping registration number, a business may receive:
- an automated assessment letter;
- letters asking for payment of any automated assessments; and
- notification of a default surcharge because the business has not filed its tax return.
The business does not need to take any action in response to any of these notices. HMRC will automatically cancel them once the group application is fully processed.
HMRC will not take recovery action for any debts listed above that come about because a business follows this guidance. Other VAT debts may still be subject to recovery actions.
Any business that followed the interim guidance, provided by HMRC on 24 November 2021, to submit VAT returns using previous registration numbers, does not need to take any steps to change this.
In all instances, unless the application is refused, the date the group becomes registered will be the date that HMRC received the application, or another agreed date. HMRC has confirmed that a business will not be penalised as a result of actions taken in response to previous versions of this guidance.