We recently advised that from mid-November 2023, HMRC will no longer be providing paper VAT1 registration forms on GOV.UK. This will only be available on request from the VAT helpline in exemption cases and certain limited scenarios where online registration is not currently possible. Businesses who are exempt from applying online will still be able to apply by post using a paper VAT1 form. Essentially the exemption from applying online mirrors that available under Making Tax Digital for VAT. HMRC has now confirmed that Monday 13 November 2023 is the date from which VAT registration applications must be made online in the majority of scenarios using the VAT registration service (“VRS”).
It has been confirmed that those who cannot apply online are not required to apply for an exemption in advance. However, when calling the VAT helpline, HMRC will ask why a paper VAT registration form is being requested.
It should also be noted that there are several specific types of VAT registration that cannot use the VRS which includes entities (except for UK partnerships or non-established taxable persons) without a unique taxpayer reference. A full list of these is not currently available.
Such businesses should call the VAT helpline to request a paper VAT1 registration form. However, HMRC is aiming to add those businesses to the VRS in future, which means that the paper VAT1 form will no longer be available once online registration via the VRS is introduced.
HMRC has also confirmed that should a digitally excluded taxpayer use the services of an agent then the application should be a digital one via the VRS.
Work is ongoing to update HMRC’s guidance pages to remove the downloadable VAT1 form, and direct taxpayers to the VRS digital route. This includes letting them know what evidence will be required to be provided in advance of starting an application, including ID verification requirements.
At a recent Joint VAT Consultative Committee Meeting, which Chartered Accountants Ireland participates in, external stakeholders asked about the move to more digital routes and if HMRC had tested this with external users, particularly for large organisations with diverse teams over a number of offices. This was particularly raised in the context of submitting online for the first time where it may not be clear what information is going to be needed to start the online form. Forms sometimes disappear after 28 days which can be an issue in larger organisations where it may take longer than this to complete the form. It is also the case that when submitting a form online, all that an employee needs to do is enter the organisation’s email address and tax reference. However, there is no scope to confirm that the submission has been made by the authorised signatory or that the authorised signatory has authorised the submission to be made on their behalf.
HMRC’s response to this is set out below.
“Prior to HMRC moving to the new VAT Registration Service extensive user research was conducted over a 3-year period with a range of users including agents. The feedback from user research was that the data being requested was reasonable and would be able to be sourced within the timescales provided. HMRC introduced the ability to ‘Save and Return’ an application. This enabling the user the time to gather relevant data if required, without the need to restart their journey again.
The length of time the application remains available is 28 days from the last log in activity, so by using the Save and Return function the length of time to complete the application will extend beyond the 28 days.
On 15 June we updated Register for VAT: How to register for VAT - GOV.UK (www.gov.uk) to include more information on what is required by someone submitting an application for VAT registration.
The VRS journey mirrors the VAT1 form and the VAT 1 completion guidance can be used to prepare applications ahead of logging into VRS. VRS asks for the person completing the form to declare the capacity in which they are doing so. Part of the HMRC Charter is that we trust the information being provided to us unless we have good reason not to.
At the point of registration, we will trust that the person submitting the form is an appropriate person to do so, though we do have validation and verification processes in place to inform that decision.
There is no long-standing relationship created by someone applying on behalf of someone else, to do so the appropriate authorisations would need to be completed.”
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