Global VAT & Indirect Tax News

On 26 January 2026, the UK Supreme Court ruled that VAT incurred on adviser fees for an exempt share sale is not recoverable. The decision applies a strict two‑stage test, rejecting the modified approach that allowed recovery based on intended use of proceeds. The ruling closes the possibility of treating such costs as general overheads to fund taxable activities.

HMRC has reset UK VAT grouping rules, allowing overseas establishments to be treated as part of a UK VAT group and removing EU case law such as Skandia and Danske Bank. The new policy reduces cross‑border VAT friction and invites businesses to correct over‑declared VAT, while expanding HMRC’s discretion to deny grouping where it sees collection risk or distortive outcomes.

The UK government announced a £92m Places of Worship Renewal Fund on 22 Jan 2026, replacing the £23m Listed Places of Worship Grant Scheme that had allowed churches to reclaim VAT on repairs. The new fund removes VAT relief, meaning churches will now have to pay the standard 20% VAT on repairs, with the previous scheme having capped VAT‑exempt repairs at £25,000. The move aims to align churches with other heritage assets but raises concerns about the financial burden on congregations.

This article outlines the tax, National Insurance and VAT implications of Christmas gifts and gift vouchers for employees and customers in the UK. It explains the trivial benefit threshold of £50, the £300 cap for directors, and the VAT treatment for gifts over £50. The guidance also covers reporting requirements such as P11D and the conditions for tax‑deductible promotional gifts.

The UK government will introduce a new electric vehicle excise duty (eVED) from April 2028, charging 3p per mile for electric cars and 1.5p per mile for plug‑in hybrids. The levy will be administered by the DVLA and integrated into the existing VED system, with a consultation deadline of 18 March 2026.

A UK court upheld HMRC's assessment and imposed a penalty of over £1 million on a private healthcare company that filed a VAT appeal late. The ruling confirms that companies must meet strict conditions to challenge VAT assessments and that late appeals can trigger significant penalties.

A UK court upheld HMRC's decision to reject a private healthcare company's late VAT appeal, confirming that the company must meet strict conditions to challenge the assessments and the £1.3 million penalty. The ruling reinforces HMRC's authority to enforce timely appeals and the penalties for late submissions.

HMRC has reversed its stance on UK VAT grouping, allowing overseas establishments of UK VAT groups to be treated as part of the group even in EU member states that do not allow whole entity VAT grouping. The change, announced on 19 January 2026, follows a November 2025 brief that also invites businesses to reclaim overpaid VAT. The shift aims to simplify cross‑border compliance and attract foreign investment, while expanding revenue‑protection rules.

The article explains the UK Cash Accounting for VAT scheme, which allows VAT-registered businesses to pay VAT only when they receive payment, aligning tax liability with cash flow. It highlights the £1.35 million projected turnover threshold, the scheme’s benefits and limitations, and ongoing discussions about raising the eligibility threshold.

HM Revenue & Customs has reversed its stance on UK VAT grouping, stating that EU case law restrictions no longer apply. The change allows overseas establishments of VAT‑grouped businesses to be treated as part of the group even in EU states that do not use whole‑entity VAT grouping, and invites firms to reclaim overpaid VAT. The policy, announced after the 2025 Budget, seeks to simplify cross‑border compliance and attract foreign investment.

The newsletter covers recent VAT developments, including a new EU customs duty for low-value parcels, a UK Supreme Court ruling affecting VAT recovery on fundraising activities, and a change in VAT treatment for locum doctors following HMRC's decision not to appeal a tribunal ruling.

The VAT Refunds Manual is an HMRC internal guidance document outlining procedures for traders to claim VAT refunds. It covers eligibility, claim requirements, time limits, verification, handling of abusive or unjust enrichment claims, end‑customer refund claims, refusal procedures, appeals, and penalties.

The UK Supreme Court ruled on 15 January 2026 that VAT on professional costs incurred in connection with a VAT‑exempt share disposal is not recoverable, rejecting any general fundraising exception. The decision applies to corporate groups where the parent provides taxable management services to a subsidiary, confirming that share sales remain within the scope of VAT but exempt, and that VAT grouping does not alter this treatment. Taxpayers must therefore plan for non‑recoverable transaction costs when restructuring or disposing of subsidiaries.

This guidance handbook from HMRC explains customs authorisations in detail, covering their purpose, eligibility, application procedures, compliance requirements, guarantee types, authorisation management, appeals, renewal, and the legal framework. It serves as a technical reference for businesses and customs officials to correctly apply for and manage customs authorisations.

The UK Supreme Court is hearing a case on whether Hotel La Tour Ltd can recover the VAT paid on professional fees incurred to facilitate the sale of shares in its subsidiary. The dispute centers on the link between the input VAT and the company’s taxable activities. The judgment, issued 17 December 2025, will clarify the recoverability of such VAT in similar share‑sale contexts.

The First‑tier Tribunal (Tax Chamber) upheld HMRC’s VAT liability ruling that Story Terrace Limited’s supplies are standard‑rated ghost‑writing services, not zero‑rated books. The decision, issued on 11 December 2025, confirms the classification under the Value Added Tax Act 1994.

The Deloitte TaxScape weekly VAT news update covers a First‑tier Tribunal ruling that allows Littlewoods to recover full input tax on photography costs, the withdrawal of HMRC’s linked‑goods concession under the ESC, and significant changes to the EU Deforestation Regulation effective 30 December 2026 for large and medium businesses. It also notes the removal of printed materials from the EUDR scope and the publication of these changes in the Official Journal on 23 December 2025.

The UK Government brief confirms that the VAT exemption for deputising services extends to all temporary medical staff, including locum doctors supplied by employment businesses, following a 2025 First Tier Tribunal ruling. Businesses that have charged standard‑rate VAT on such supplies within the last four years can claim a refund via an error‑correction notification. The brief also outlines the steps for claiming refunds and the impact on recovered input tax.

The UK First‑Tier Tax Tribunal ruled on 16 December 2025 that photography costs used for product catalogues and an online store by an online retailer with integrated financial services are fully recoverable input VAT, as they are used for taxable retail supplies. The decision clarifies that such costs are not partially recoverable due to mixed use with exempt financial services.

The UK First‑Tier Tax Tribunal clarified that caregivers supplied to nursing and residential care homes are not VAT‑exempt unless they are registered medical professionals or supervised as required. The tribunal found that the taxpayer's services did not meet the exemption criteria and no other exemptions applied. The decision was issued on 16 December 2025.