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    Bloomberg Tax
    January 16, 2026 (about 2 months ago)

    UK VAT Grouping Policy Shift Aims to Attract Foreign Investment

    Featured image for: UK VAT Grouping Policy Shift Aims to Attract Foreign Investment
    United Kingdom VAT News • Bloomberg Tax

    Summary

    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.

    Key Insights

    What did HMRC reverse regarding UK VAT grouping rules?

    HMRC reversed its position that EU case law restrictions applied to UK VAT grouping, allowing overseas establishments of VAT‑grouped businesses to be treated as part of the group even in EU states without whole‑entity VAT grouping.

    When did HMRC announce the policy shift?

    The announcement followed the 2025 Budget and was published in Revenue and Customs Brief 7 (2025).

    What opportunity does the policy shift provide for businesses that previously followed older guidance?

    HMRC invited businesses that had accounted for VAT under the 2015 guidance to submit error correction notices to reclaim overpaid VAT.

    How has HMRC updated its definition of "protection of the revenue"?

    HMRC expanded the definition in VAT Notice 700/2 to include enhanced risks to revenue collection and distortion in the liability of the group’s supplies.

    Europe
    United Kingdom
    Compliance
    Court Rulings
    Cross-Border
    VAT Update
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