HMRC have published Revenue and Customs Brief 5 (2022): ‘Revised guidance on dealing with VAT grouping registration’. This replaces guidance issued in November 2021 and explains the actions businesses should now take when filing VAT returns while waiting for a decision on their VAT grouping application. 


In November 2021, HMRC issued guidance for businesses submitting VAT returns while waiting for a decision on VAT grouping applications.

  • This guidance was broadly to file returns as normal, as though the application was not happening.
  • When the application was processed, adjustments may then have been required to reflect changes to the VAT group from the date intended.

This guidance has now changed.

Current position

Businesses waiting for a VAT grouping application to be processed should now:

  • Treat the application as provisionally accepted on the date it:
    • Was submitted online, or
    • Should be received by HMRC, if submitted by post.
  • Account for VAT accordingly.

Businesses waiting to receive a VAT grouping registration number may receive other communications, such as:

  • An automated Assessment letter.
  • Letters asking for payment of any automated assessments.
  • Notification of a Default surcharge because they have not filed their VAT return.

No action is required in respect of these notices. They will be automatically cancelled once the group application is fully processed.

  • Recovery action will not be taken for debts listed above that arise from following the new guidance.
  • Other VAT debts may still be subject to recovery action.

Previous guidance

Where businesses have followed the November 2021 guidance:

  • No action is required where VAT returns have been submitted using previous VAT registration numbers.
  • Unless the grouping application is refused, the date a business becomes Registered will be the date that HMRC received the application or another agreed date.

Useful guides on this topic

What are the conditions for forming a VAT group? What rules apply once a VAT group is in place? 

Registering for VAT
When should a business register for and charge VAT? What are the VAT registration limits and VAT rules after Brexit? What penalties might HMRC issue for late notification of registration? 

Penalties (VAT)
When do penalties apply for VAT? What penalties are charged and how can they be mitigated?

Assessments: Best judgement
What is a 'best judgement' assessment for VAT? When can HMRC raise one? What are your rights of appeal? How do you displace a best judgement assessment?

Is voluntary VAT registration worthwhile?
When can a business voluntarily register for VAT? When would it be beneficial to voluntarily register?

External link

Revenue and Customs Brief 5 (2022): ‘revised guidance on dealing with VAT grouping registration’

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