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RCB 7 (2025): HMRC Revises VAT Grouping Rules After Skandia Judgment

  • HMRC published Revenue and Customs Brief 7 (2025) revising VAT grouping rules for overseas establishments in UK VAT groups, following the Skandia judgment.
  • From 26 November 2025, overseas establishments of UK VAT group members will be treated as part of the UK VAT group, even if located in EU countries with ‘establishment-only’ VAT grouping regimes.
  • This change reverses previous HMRC guidance that required certain intra-entity supplies to be treated as taxable and subject to the reverse charge.
  • Businesses that overpaid VAT under the old rules are invited to submit error correction notifications to reclaim overpaid amounts.

Source: taxscape.deloitte.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.



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