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HMRC Updates VAT Recovery Rules for Pension Scheme Services

  • HMRC has updated its guidance on VAT recovery for funded occupational pension scheme services after Revenue and Customs Brief 4 (2025).
  • Employers can now recover VAT on scheme-related services only if they directly contracted for those services; the old distinction between administration and investment services has been removed.
  • The previous 70/30 VAT split for mixed services is no longer accepted.
  • HMRC now points to “onwards supply” arrangements, where trustees receive services and supply them onward to the employer, as a possible route to VAT recovery.
  • The guidance applies from 18 June 2025, even though it was published later.

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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