HMRC have published 'Revenue & Customs Brief 8 (2026): UK VAT refunds for non-UK businesses in a VAT group'. It explains changes to how non-UK businesses in a VAT group should make future UK VAT refund claims, including transitional arrangements and how to ask HMRC to reconsider claims made since 1 January 2021 that have been refused.
The brief is relevant to:
- Non-UK businesses that are members of a VAT group and want to claim a refund of UK VAT.
- Non-UK businesses that are members of a VAT group and have had a UK VAT refund claim rejected because the representative member did not submit the claim.
- Agents who submit UK VAT refund claims on behalf of non-UK businesses that are members of a VAT group.
The issue
Non-UK businesses can use the overseas VAT refund scheme to claim back UK VAT if they meet the scheme conditions. Before Brexit, the position was as follows:
- Businesses established outside the EU had to submit claims through the VAT group’s representative member, even if that representative member had not incurred the UK VAT.
- In some circumstances, businesses established in the EU could submit claims in their own name.
Since 1 January 2021, all non-UK businesses that are members of a VAT group have had to submit claims through the group representative member.
- As a result, some EU VAT group members have no longer been able to submit claims in their own name. This has meant that in some cases, such as where the representative member was registered for VAT in the UK, the business that incurred the UK VAT has not been able to claim a refund.
This was an unintended consequence of the UK’s exit from the EU.
The solution
The current changes will allow all eligible non-UK businesses to claim refunds of UK VAT in the same way, whether they are in the EU or elsewhere, as follows:
- All non-UK businesses that are members of a VAT group can and must submit their own claim for any UK VAT they incur.
- HMRC will not accept claims from a representative member unless that representative member incurred the VAT.
As a transitional measure, HMRC will accept claims for VAT incurred in the period 1 July 2025 to 30 June 2026 (the 2025-26 prescribed year) from either:
- the individual VAT group member that incurred the VAT; or
- the representative member of the VAT group.
The deadline for submitting claims for the 2025-26 prescribed year is 31 December 2026.
How to deal with claims that have been rejected by HMRC
HMRC have said they will review claims for VAT incurred from 1 January 2021 that have previously been rejected because the representative member did not submit the claim and provided that the VAT was not included in a later claim submitted by the representative member.
- To ask HMRC to review a claim, taxpayers should email the Overseas Repayments Unit at
This email address is being protected from spambots. You need JavaScript enabled to view it. using the subject line: ‘Reconsideration of a previously refused VAT group claim’ and including the following information in their email:- The business name.
- The unique reference number issued by the Overseas Repayments Unit and the claim number.
- The claim period, claim value and the date of the decision letter.
- The full names of all VAT group members during the claim period.
- A statement confirming that the VAT was not included in a later claim.
- The deadline for asking HMRC to review a claim is 31 August 2027. This is a hard deadline as HMRC have stated that they will not consider any review requests received after this date.
Useful guides on this topic
Groups (VAT)
What are the conditions for forming a VAT group? What rules apply once a VAT group is in place?
International goods
Special VAT rules apply to goods bought from and sold to non-UK businesses.
Importing goods into GB from 1 January 2021
The post-Brexit transition period ended on 31 December 2020. HMRC issued guidance for importing goods.
External links
Policy paper: Revenue & Customs Brief 8 (2026): UK VAT refunds for non-UK businesses in a VAT group
HMRC Guidance: Refunds of UK VAT for non-UK businesses (VAT Notice 723A)