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HMRC internal manual

VAT Government and Public Bodies

Other local authority activities: miscellaneous (A to E): Criminal Records Bureau checks

The Criminal Records Bureau (CRB) is a statutory body whose charges are non-business. Although it is possible for enquiries to be made directly to the CRB, it is more usual for them to be passed via an ‘umbrella body’ which is often a local authority registered with the CRB. This umbrella body checks that application forms have been correctly completed and may also collect the fees on behalf of the CRB.

Collection of the CRB fee by an authority may be treated as a disbursement so long as the normal rules are satisfied. For more information see the VAT Taxable Person Manual (VTAXPER) (external users can find the guidance at But any charge the authority might make for the administration service in handling an application is by way of business and so is standard rated.

On occasions a local authority may require a CRB check as part of a licensing procedure. For example the Local Authorities (Miscellaneous Provisions) Act 1976 requires minicab drivers and operators to be licensed by a local authority. In that case any administration charge made by the authority to the applicant relates to the authority’s duty to verify the status of that applicant. It is not subject to VAT as it relates to the authority’s non-business licensing function.