VAT group registration

By Tolley

The following Value Added Tax guidance note by Tolley provides comprehensive and up to date tax information covering:

  • VAT group registration
  • What is a VAT group?
  • Advantages and disadvantages
  • Conditions
  • Specified bodies and protecting the revenue
  • Group registration procedure

This document discusses these in detail, together with the advantages and disadvantages of forming a VAT group; the relevant conditions for joining a VAT group; and the group registration procedure.


This note provides an overview of the main VAT rules concerning businesses that intend to register as part of a VAT group. This note should be read in conjunction with the VAT groups ― specified bodies and protection of the revenue and Divisional registration guidance notes. Detailed information can be found in HMRC registration manual VGROUPS01000.

Update: please note that HMRC published a consultation  document in December 2016 regarding the scope of VAT grouping as the result of several influential CJEU judgements. HMRC has reviewed the responses received and the draft Finance Bill 2018–19  legislation and explanatory notes have been published which contains draft clauses relating to VAT grouping.

Clause 18 and Schedule 10 contain measures to amend the current VAT grouping eligibility rules and non-corporate entities, such as partnerships and individuals, will be allowed to join a VAT group if they meet the relevant conditions. The changes will come into effect after the date of Royal Assent on a date appointed by the Treasury.

What is a VAT group?

Two or more body corporates (see below) can elect to VAT register as a single taxable entity using the same VAT registration number if they meet the relevant requirements.

VATA 1994, s 43A; De Voil Indirect Tax Service V2.190 (subscription sensitive); SI 2004/1931 (subscription sensitive); EC Directive 2006/112 , Art 11; VGROUPS01000; Notice 700/2 

The entity must:

  • have an establishment in the UK
  • be under common control. The definition of control is based on the definition of a holding company and subsidiary in Companies Act 2006, s 1159, and Sch 6


  • satisfy the conditions outlined below

A VAT group can be formed if one of the members is making supplies that would be liable to register

More on Group and divisional registration: