V7.165 Rules for group registration
Under UK law, for a VAT group to be formed, the proposed members of the group must be eligible to join. From 1 November 2019, an entity is eligible to join or form a VAT group if it is a corporate body (ie a company) if it is established or has a fixed establishment in the UK, is under 'common' control and does not meet certain anti-avoidance conditions specified by HMRC to avoid the VAT grouping rules from being exploited for an unfair tax advantage.
For non-corporate bodies (ie individuals or partnerships – including Scottish partnerships), they are eligible to join or form a VAT group if they control the UK corporate body or all of the corporate bodies within a VAT group, they carry on a business activity making supplies of goods or services (or both) and they are established or have a fixed establishment in the UK.
An individual or partnership controls a UK body corporate if it would, as a company, be the