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Non-UK VAT groups: check who should submit a UK VAT refund claim
HMRC has changed its position for UK VAT incurred by non-UK VAT-group members. Check the claimant, prescribed year and evidence before relying on a representative-member claim.
The claimant is the member that incurred the VAT
HMRC’s 8 September 2026 brief says each non-UK business in a VAT group must submit its own claim for UK VAT it incurred. HMRC will not accept a representative-member claim unless that representative member incurred the VAT.
The change concerns eligible users of the overseas VAT refund scheme. The business must still meet the scheme conditions, including not being UK-established, UK VAT-registered or liable or eligible to register, subject to the exceptions HMRC lists.
Use the transitional rule carefully
For VAT incurred in the 2025 to 2026 prescribed year, running from 1 July 2025 to 30 June 2026, HMRC says it will accept a claim from either the member that incurred the VAT or the representative member. The deadline stated in the brief is 31 December 2026.
Separate the transitional claim from later periods in your working papers. Match each invoice to the member that incurred the VAT, the prescribed year and the claim route; do not treat a group chart alone as evidence of who paid the VAT.
Revisit a previously refused claim
HMRC says it will review certain claims for VAT incurred from 1 January 2021 that were rejected because the representative member submitted them, provided the VAT was not included in a later claim. The review request has its own information requirements and a 31 August 2027 deadline.
Keep the original decision, claim number, claim period, value and member list together. This article is a records checklist, not a conclusion that a refund is due.
Sources
- HM Revenue & Customs — UK VAT refunds for non-UK businesses in a VAT group (2026-09-08)