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HMRC internal manual

VAT Groups

Eligibility conditions for specified bodies: specified bodies: who is a 'third party'?

A third party is any person or partnership except:

  • anyone who controls the whole VAT group (using the meaning of control described in VGROUPS02150). This includes both direct holding companies and indirect holding companies, all the way up to the ultimate controlling person;
  • anyone controlled by a person who controls the group. This therefore includes all fellow-subsidiaries;
  • any individual who is a director or employee of the body corporate;
  • where the body corporate is a limited liability partnership, any individual who is a partner in the partnership.

Broadly speaking, any person outside the corporate group that includes the VAT group is a third party, except individuals working for the body corporate itself.