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HMRC internal manual

VAT Government and Public Bodies

HM Revenue & Customs
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Section 33 bodies: registration and accounting: group VAT registration

It is unusual for section 33 bodies (including local authorities and their joint boards or committees) to meet the criteria for a group VAT registration. For more information about this see Notice 700/2’Group and divisional registration’ (external users can find the notice at However, if exceptionally the requirements for group treatment are met, then claims for non-business activities are restricted to those undertaken by the section 33 body itself and not the group as a whole.

Group registrations in these circumstances are not eligible for the special treatment provided by section 33(2) for VAT on purchases for exempt activities (see VATGPB4510). The group as a whole is subject to the normal partial exemption rules - see Notice 706 ’Partial exemption’
(external users can find the notice at