VATDREG15000 - Re-registration after cancellation

If a person has been deregistered in error and the application has been processed, there are two possible actions:
• Reinstate the original VAT Registration Number (VRN) – provided we have the person’s agreement
• Re-register the person – if they are liable to be registered or request to be registered

Reinstatement
The VAT Act 1994 does not explicitly provide for reinstatement once a person has been deregistered. However, as an administrative easement, HMRC may reinstate a person’s VRN with their consent. HMRC cannot compel reinstatement.

Reinstatement has the effect of treating the registration as continuous, as if the person had never been deregistered. Standard practice allows reinstatement within six months of the effective date of cancellation. In exceptional cases, a shorter or longer period may be considered, depending on the specific circumstances. There is no right of appeal against a decision not to reinstate.

A person who was deregistered in error but does not have a liability to register may still request reinstatement, provided they have an entitlement to be registered.

Re-registration – Schedule 1
If reinstatement is not agreed or deemed inappropriate, the person must be re-registered under the normal rules if the person is liable to be registered.

Under Schedule 1 of the VAT Act 1994, this will depend on the value of their supplies using:
• The backward look test – see VATREG18100
• The forward look test – see VATREG18200

Key Considerations:
VATREG18150: When determining liability to register, do not include turnover from the previous registration period unless the person misled HMRC or withheld information at the time of deregistration
VATREG25100: If liability is established, the earliest re-registration date is the first day of the second month following the date liability arose. This will create a gap between the old and new registration where the customer was not liable to account for VAT.
• Under the forward look, the effective date of registration may be immediately after deregistration if there is evidence available at that time the taxable turnover will exceed the threshold in the next 30 days

Example:
On 22 April, a person deregistered but had misled the department when stating their liability to register had ceased. As a result, we can include their taxable turnover in their previous period of registration when calculating their liability to be registered.
If we have their agreement, the original VAT number can be immediately reinstated.
If we do not have agreement to reinstate, we must re-register the person subject to the normal rules.

Timeline Event Date
Registration threshold exceeded 22 April
Trader becomes liable to register 30 April
Effective date of registration (EDR) 1 June

Re-registration - Schedule 1A and 3A
Under Schedules 1A and 3A, the effective date of registration is the date liability arose, allowing immediate re-registration from the date following the effective date of cancellation of their previous registration.