Restructure without treating VAT as an afterthought.

VAT grouping, transfers of going concerns, legal-entity changes and transaction implementation for business change.

Discuss your position
01Map entities and supplies
02Test grouping or TOGC conditions
03Model recovery and liability
04Sequence applications and completion
01

VAT groups change who accounts for tax

A VAT group is treated as a single taxable person for many VAT purposes. The representative member accounts for the group, intra-group supplies are generally disregarded, and members can carry joint and several liability.

  • Eligibility and control
  • Representative-member responsibility
  • Joining and leaving dates
  • Partial exemption and group recovery
02

TOGC treatment is mandatory when conditions are met

A transfer of a business or part of a business can fall outside the scope of VAT when the assets form an operating business and the buyer continues the same kind of activity. Property, registration and consecutive-transfer conditions require early attention.

  • Asset and activity continuity
  • Buyer registration
  • Property option-to-tax conditions
  • Contract and completion sequencing
03

A registration number does not solve the transaction

Applications, elections, VAT68 treatment, final returns and system cutovers need to follow the legal change. An implementation plan should assign each action and effective date.

  • New legal entities
  • Group applications
  • Registration-number transfer
  • Opening and closing return controls
Primary sources

Tax guidance changes. These official sources were checked on 31 August 2026.

VAT Notice 700/2: group registrationVAT Notice 700/9: transfer of a going concernVAT Notice 700/1: registration
Important

This page provides general information, not advice for a particular transaction. VAT treatment depends on the complete facts and current law.