RCB/1/17 VAT—historical bad debt relief claims

Part V16 Forms and other HMRC material

RCB/1/17 VAT—historical bad debt relief claims

RCB/1/17 VAT—historical bad debt relief claims

Revenue & Customs Brief, Issue 1. 28 March 2017

Purpose of this brief

This brief sets out HM Revenue and Customs' (HMRC) position on claims for historical bad debt relief following the Court of Appeal's judgments in British Telecommunications of 11 April 2014 and GMAC UK Plc on 25 October 2016.


VAT registered businesses that suffered bad debts on supplies they made between 1 January 1978 and 19 March 1997 and that didn't adjust the VAT on such debts.


The UK VAT Bad Debt Relief scheme was introduced in 1978. Since then the conditions of the scheme have changed:


    —     before 1 April 1989, the scheme required the defaulting customer to be formally insolvent


    —     until 19 March 1997, there was also a condition that title in any goods must have

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