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Q: We have submitted a new VAT group application for our client. Two members are already separately VAT registered but the other two are not. HMRC have acknowledged the application however we hear that these are taking some time to process and issue a new VAT group number and first group VAT return. We have heard conflicting information as to what to do in the meantime and wondered if you had any thoughts on this?

A: In March 2022 HMRC released Revenue and Customs Brief 5 (2022) and updated paragraph 2.19 of VAT Notice 700/2 to give clarity on this. The conflicting advice have seen may have been as a result of previous guidance issued by HMRC that it has now changed! Essentially HMRC now ask you to treat the application as though it has been provisionally accepted (from date of submission or date received by HMRC) and to account for VAT as a VAT group from that point and any members with pre-existing VAT registrations should stop doing VAT returns and issuing VAT invoices. HMRC's systems will likely send central assessments for VAT returns not submitted but current guidance is to not pay these; HMRC will cancel them once the group application has been processed and will not chase for payment. It might still be advisable to contact HMRC's business payment support service to explain these non-payments just in case they start recovery action in error. Any sales made after the provisional effective date fall under the VAT group so any VAT invoices will need to show the VAT group's new VAT number. While waiting for this, any invoices issued must not show the VAT separately but can be for the gross amount with 'VAT Number applied for'. Once the VAT number is received the invoices can be credited and replaced with VAT invoices and the VAT return completed and paid for the group. Where members have followed HMRC's previous advice and submitted returns ignoring the VAT grouping, there is no need to change this.

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Markel Tax offers expert advice on UK tax and VAT via its helpline and provides monthly FAQs with questions and answers on common tax issues for businesses and practitioners.