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HMRC internal manual

VAT Government and Public Bodies

Introduction: how to use the manual

If you are uncertain whether you are dealing with a body governed by public law your starting point should always be VATGPB2000. This explains when a body can be treated as one ‘governed by public law’. If that test is not met then the rest of the content of the manual will not apply.

If you are already satisfied that you are dealing with a body governed by public law, then VATGPB2300 provides guidance on activities that are treated as non-taxable or, what is more generally referred to as, ‘non-business’.

You will first need to consider whether an activity is non-business before considering eligibility for the refund scheme (see VATGPB4100) as this only applies to non-taxable activities.

This manual does not cover general aspects of VAT such as liability and so you may need to consult other sources of guidance. For example, when considering if VAT is recoverable it may also be necessary to refer to the VAT Input Tax Manual (VIT) (external users can find the guidance at

References to ‘section 33 bodies’ elsewhere within this manual are to bodies who qualify for refunds under section 33 of the VAT Act 1994 (see VATGPB4000)