Policy paper

UK VAT refunds for non-UK businesses in a VAT group

Published 8 September 2026

Purpose of this brief

This brief explains changes to how non-UK businesses that are members of a VAT group can claim refunds of UK VAT.

Who should read this brief

This brief is for:

• non-UK businesses that are members of a VAT group and want to claim a refund of UK VAT
• non-UK businesses that are members of a VAT group and have had a UK VAT refund claim rejected because the representative member did not submit the claim
• agents who submit UK VAT refund claims on behalf of non-UK businesses that are members of a VAT group

Background

Non-UK businesses can use the overseas VAT refund scheme to claim back UK VAT if they meet the scheme conditions.

A business must:

• not be registered for VAT in the UK
• not be liable or eligible to register for VAT in the UK
• not have a business establishment or other fixed establishment in the UK
• not make supplies in the UK, except for certain transport services or supplies where the customer accounts for the VAT

Before 1 January 2021, HMRC applied different rules to VAT refund claims from businesses that were members of a VAT group in their country of establishment. The rules depended on whether the business was established in the EU or outside the EU.

Businesses established outside the EU had to submit claims through the VAT group’s representative member, even if that representative member had not incurred the UK VAT. In some circumstances, businesses established in the EU could submit claims in their own name.

From 1 January 2021, all non-UK businesses that were members of a VAT group had to submit claims through the representative member. As a result, some EU VAT group members could no longer submit claims in their own name. In some cases, such as where the representative member was registered for VAT in the UK, the business that incurred the UK VAT could not claim a refund.

This was an unintended consequence of the UK’s exit from the EU. These changes restore the previous position and allow all eligible non-UK businesses to claim refunds of UK VAT in the same way.

Details

All non-UK businesses that are members of a VAT group must submit their own claim for any UK VAT they incur. HMRC will no longer accept claims from a representative member unless that representative member incurred the VAT.

As a transitional measure, HMRC will accept claims for VAT incurred in the 2025 to 2026 prescribed year (1 July 2025 to 30 June 2026) from either:

• the individual VAT group member that incurred the VAT
• the representative member of the VAT group

The deadline for submitting claims for the 2025 to 2026 prescribed year is 31 December 2026.

HMRC will also review claims for VAT incurred from 1 January 2021 that it rejected because the representative member did not submit the claim, provided the VAT was not included in a later claim submitted by the representative member.

To ask HMRC to review a claim, email the Overseas Repayments Unit at newcastle.oru@hmrc.gov.uk.

Use the subject line: ‘Reconsideration of a previously refused VAT group claim’.

Include the following information in your email:

• the business name
• the unique reference number issued by the Overseas Repayments Unit and the claim number
• the claim period, claim value and the date of the decision letter
• the full names of all VAT group members during the claim period
• a statement confirming that the VAT was not included in a later claim

You must ask HMRC to review a claim by 31 August 2027. HMRC will not consider requests received after this date.

Further information

Read VAT Notice 723A: Refunds of UK VAT for non-UK businesses for more information.

If you have questions about this change, email HMRC at newcastle.oru@hmrc.gov.uk.