VAT Cost Sharing Exemption Manual

Updates: VAT Cost Sharing Exemption Manual

2026

5 March 2026

Introduction: When does the Cost Sharing Exemption apply?

Example included on page - this is also in an attachment which will be replaced in due course.

2021

7 September 2021

Introduction: When does the Cost Sharing Exemption apply?

EU Exit changes

EU Exit changes

Introduction: What is the legal basis for the exemption?

EU Exit changes

Introduction: When did the exemption become effective in UK legislation?

EU Exit changes

General provisions: contents

Page CSE2500 archived

General provisions: can a UK established CSG have members in third countries and can a UK business or organisation belong to a CSG established outside the UK

EU Exit changes

General provisions: Do EU Procurement Directives apply?

Page archived - guidance no longer applicable

How the condition are to be interpreted: Independent Group of Persons: What is a Cost Sharing Group (CSG)?

EU Exit changes

How the conditions are to be interpreted: Number of members and memberships: What are “qualifying supplies”?

EU Exit changes

How the conditions are to be interpreted: Exempt and/or non-business activities: Do all members have to have exempt and/or non-business activities?

EU Exit changes

How the conditions are to be interpreted: Exempt and/or non-business activities: What are exempt supplies?

EU Exit changes

How the conditions are to be interpreted: Directly Necessary services: What are ‘directly necessary’ services? (guidance effective until 14 August 2018)

EU Exit changes

How the conditions are to be interpreted: Directly Necessary services: How may ‘directly necessary’ services be identified? (guidance effective until 14 August 2018)

EU Exit changes

How the conditions are to be interpreted: Directly Necessary services: How does the 85% “directly necessary” test work? (guidance effective until 14 August 2018)

EU Exit changes

How the conditions are to be interpreted: Directly Necessary services: How can the test be applied in practice? (guidance effective until 14 August 2018)

EU Exit changes

Directly Necessary services: What will happen if a member meets the 85% test by having an intention to make 85% or more exempt and/or non-business supplies in the following 12 month period but that (guidance effective until 14 August 2018)

EU Exit changes

How the conditions are to be interpreted: Directly Necessary services: What happens if a member fails the 85% test after initially meeting the test? (guidance effective until 14 August 2018)

EU Exit changes

How the conditions are to be interpreted: Directly Necessary services: Can the 85% test be applied on a sector/account basis? (guidance effective until 14 August 2018)

EU Exit changes

How the conditions are to be interpreted: Directly Necessary services: What are ‘directly necessary’ services? (guidance effective from 15 August 2018)

EU Exit changes

How the conditions are to be interpreted: Direct Reimbursement of Costs: If the direct tax transfer pricing rules apply will they preclude use of the exemption as affected transactions may not comply with the 'exact reimbursement of costs' rule?

EU Exit changes

How the conditions are to be interpreted: Distortion of competition: How can the exemption lead to a ‘distortion of competition’?

EU Exit changes

2020

10 July 2020

Introduction: Application of the Cost Share Exemption to Social Housing Organisations: General Position

correction to page reference

9 July 2020

Introduction: contents

CSE1080 added to contents

re-saving

Introduction:Conditions for application of the CSE to CSGs in the social housing sector

Duplicated page

23 June 2020

Introduction: contents

update

19 June 2020

Introduction: Application of the Cost Share Exemption to Social Housing Organisations: General Position

update

update

update on the application of the Cost Share Exemption to Social Housing Organisations - General Position

2018

14 December 2018

How the conditions are to be interpreted: ‘Directly Necessary’ services: Requirement for the CSG to have a partial exemption method? (guidance effective from 15 August 2018)

update

How the conditions are to be interpreted: ‘Directly Necessary’ services: How may ‘directly necessary’ services be identified? Use of special methods by members of CSGs (guidance effective from 15 August 2018)

update

How the conditions are to be interpreted: ‘Directly Necessary’ services: Requirement to be VAT registered? (guidance effective from 15 August 2018)

Update

31 July 2018

How the conditions are to be interpreted: ‘Directly Necessary’ services: contents

revised index

Update following CJEU decisions in 2017.

Update following CJEU decisions in 2017.

Update following CJEU decisions in 2017.

Update following CJEU decisions in 2017.

Update following CJEU decisions in 2017.

Update following CJEU decisions in 2017.

Update following CJEU decisions in 2017.

Update following CJEU decisions in 2017.

Update following CJEU decisions in 2017.

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Directly Necessary services: What are ‘directly necessary’ services? (guidance effective from 15 August 2018)

update

How the conditions are to be interpreted: ‘Directly Necessary’ services: Requirement for the CSG to have a partial exemption method? (guidance effective from 15 August 2018)

Update

update

How the conditions are to be interpreted: ‘Directly Necessary’ services: How may ‘directly necessary’ services be identified? Use of special methods by members of CSGs (guidance effective from 15 August 2018)

Update

Update

CSE3890 - How the conditions are to be interpreted: ‘Directly Necessary’ services: Issue of VAT invoices by CSG? (guidance effective from 15 August 2018)

Update

Update

update

How the conditions are to be interpreted: ‘Directly Necessary’ services: Requirement to be VAT registered? (guidance effective from 15 August 2018)

Update

2 July 2018

Introduction: contents

Update review date

Introduction: When does the Cost Sharing Exemption apply?

Revise Review Date

Introduction: What is the legal basis for the exemption?

Revise review date

Introduction: What types of exempt businesses and organisations can benefit from the exemption with effect from 1 June 2018?

Revise review date

Revise Review Date

Introduction: What types of exempt businesses and organisations could benefit from the exemption prior to 1 June 2018?

Revise review date

Revised Review Date

Introduction: What non-business activities of members could benefit from the exemption?

Update review date

Introduction: Application of the Cost Share Exemption to Social Housing Organisations: General Position

Update review date

Introduction: When did the exemption become effective in UK legislation?

Revised review date

Introduction: What is meant by ‘members’ of a CSG?

Publish on internet

Introduction: What are the conditions of the exemption?

Publish on internet

Introduction: Does the exemption apply to outsourced services?

Update review date

General provisions: Does the exemption apply in any other circumstances?

Publish on internet

General provisions: can a UK established CSG have members in third countries and can a UK business or organisation belong to a CSG established outside the UK

Publish in internet

How the condition are to be interpreted: contents

Revise r3eview date

21 June 2018

How the condition are to be interpreted: Independent Group of Persons: What is a Cost Sharing Group (CSG)?

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Number of members and memberships: Are there any limits on the number of members a CSG can have?

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Number of members and memberships: Has HMRC put any special process or compliance arrangements in place?

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Number of members and memberships: What are “qualifying supplies”?

Update following CJEU decisions in 2017

How the conditions are to be interpreted: Exempt and/or non-business activities: Do all members have to have exempt and/or non-business activities?

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Exempt and/or non-business activities: Can businesses and organisations that are not VAT registered join a CSG?

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Exempt and/or non-business activities: What are exempt supplies?

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Directly Necessary services: What are ‘directly necessary’ services? (guidance effective until 14 August 2018)

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Directly Necessary services: How may ‘directly necessary’ services be identified? (guidance effective until 14 August 2018)

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Directly Necessary services: How does the 85% “directly necessary” test work? (guidance effective until 14 August 2018)

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Directly Necessary services: How can the test be applied in practice? (guidance effective until 14 August 2018)

Update following CJEU decisions in 2017.

Directly Necessary services: What will happen if a member meets the 85% test by having an intention to make 85% or more exempt and/or non-business supplies in the following 12 month period but that (guidance effective until 14 August 2018)

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Directly Necessary services: What happens if a member fails the 85% test after initially meeting the test? (guidance effective until 14 August 2018)

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Directly Necessary services: Can the 85% test be applied on a sector/account basis? (guidance effective until 14 August 2018)

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Direct Reimbursement of Costs: What is meant by ‘direct reimbursement of costs’?

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Direct Reimbursement of Costs: How are charges for management and similar services to be treated?

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Direct Reimbursement of Costs: What is transfer pricing and does it apply to services supplied by a CSG to its members?

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Distortion of competition: contents

CSE4160 page archived.

How the conditions are to be interpreted: Distortion of competition: How can the exemption lead to a ‘distortion of competition’?

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: ‘Distortion of competition’: What about commercial operators?

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: Distortion of competition: What are the practical implications of the Taksatorringen Case?

Page archived.

How the conditions are to be interpreted: CSGs and VAT Groups: Can a VAT group Registration be a member of a CSG?

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: CSGs and VAT Groups: Can a CSG be a member of a VAT group?

Update following CJEU decisions in 2017.

How the conditions are to be interpreted: CSGs and VAT Groups: How do CSGs and VAT groups interact in practice?

Update following CJEU decisions in 2017.

20 June 2018

General provisions: contents

update

Update following CJEU decisions in 2017.

Update following CJEU decisions in 2017.

Links to CSE2300, CSE2350, CSE2400, and CSE2450 archived.

General provisions: Does the exemption apply in any other circumstances?

Update

General provisions: Can a UK established CSG have members in other Member States (OMS) and can a UK business or organisation belong to a CSG established in OMS?

Page archived .

General provisions: Do the normal place of supply rules apply?

Page archived.

General provisions: What is the input tax treatment in relation to supplies to overseas customers?

Page archived.

Update following CJEU decisions in 2017.

General provisions: What does this mean in relation to supplies received by a UK member of a CSG based in another Member State?

Page archived .

8 June 2018

Introduction: contents

Update

Page archived - Update following CJEU judgements in 2017.

Links to CSE1050 archived

Introduction: What is the legal basis for the exemption?

update

Update

Introduction: What is the Cost Sharing Exemption?

Update following CJEU decisions in 2017.

Introduction: What is meant by ‘members’ of a CSG?

Update

Introduction: What are the conditions of the exemption?

Update

Introduction: Does the exemption apply to outsourced services?

Update

Introduction: What types of businesses and organisations can benefit from the exemption?

Page archived.

Introduction: When did the exemption become effective in UK legislation?

Page archived.

Introduction: What is the new Group 16 to Schedule 9 of the VAT Act 1994

Page archived - Update following CJEU judgements in 2017.

7 June 2018

Introduction: contents

Update following CJEU judgments

Update following CJEU judgments

Update following CJEU judgments

Update following of CJEU judgments

Update following of CJEU judgments