The Institute is represented on two HMRC VAT forums; the Joint Vat Consultative Committee (“JVCC”) and the VAT Registration Sub-Group forum. Recent updates from each are set out below.
The JVCC is an HMRC forum to exchange views between HMRC and representative bodies and other organisations relating to the procedures and operations of VAT, and to consider and discuss VAT issues arising from member organisations with the aim of strengthening HMRC’s understanding of the needs of the business/taxpayer. The minutes from the 125th JVCC meeting have been published and are available on GOV.UK.
The JVCC has also been advised that the new VAT Tertiary Legislation manual is now available. Except for margin scheme content, nothing in the manual new as it has all been published previously on GOV.UK. The revised margin scheme tertiary legislation is available in the manual for the first time following the withdrawal of VAT Notice 718.
To date, HMRC has not removed any force of law content from VAT Notices and so, much of it is duplicated in both this manual and its original home on GOV.UK. In due course, HMRC aims to remove legal content from its VAT Notices and replace it with plain English, where appropriate.
In the new manual, HMRC has aimed to maintain a logical structure and has included heading numbers for ease of reference. As the manual is new, HMRC is seeking feedback using the buttons in the manual.
VAT registration Sub-Group forum
Details of action points and HMRC responses from the January 2024 meeting of this forum are set out below.
A member asked whether the guidance made it clear that customers might need multiple authorisations for VAT.
This has been investigated and a change to the wording of the guidance was required and has been instigated. The guidance will be updated.
Can the VAT50 and VAT51 forms be uploaded and added to the application at the end of the online VAT registration process?
The VAT 50/51 can be either attached at the point of submission of the VAT registration within the digital journey, or taxpayers can choose to send this to HMRC via post. HMRC’s preference is that these forms are uploaded via the Vat Registration Service (“VRS”) if the taxpayer or their agent is able to do so.
Can a review be carried out regarding virtual offices and the principal place of business?
A review has been instigated and is currently ongoing. Details will be shared when an update is available.
Were specified supplies included when the previous review was carried out on compulsory registration?
HMRC has updated the rules behind the VRS to take account of these. When a person applying under these circumstances enters the words ‘SPECIFIED SUPPLIES’ in the ‘Business Descriptions’ free text box, the application will not be rejected.
HMRC has updated section 2.7 of VAT Notice 700/1 to this effect and is considering the most appropriate place to include an update in the VRS itself to best support applications.
Does the registration team no longer send out confirmation of registration changes?
VAT registration and variation outputs are generated automatically and issued to the taxpayer when the application or variation has been processed; there is no manual process to issue an output to provide the same confirmation.
HMRC provided an update regarding queries that have been made in relation to Parish Councils and Public Bodies as follows:-
“Applications for VAT registration from public bodies should be made on a paper VAT1 as per current guidance. When we can introduce a bespoke journey into the online VAT Registration Service, we will communicate this via the appropriate channels, but there are currently no plans for this.”
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