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HMRC internal manual

VAT Groups

Applications for VAT group treatment: refusal of retrospection - registration of applicants

The refusal of an application for retrospective group treatment does not remove the need for the applicants concerned to register if they were liable to do so prior to the date we allow for the group registration. The High Court decision in the case of Save & Prosper Group Ltd QB July 1978, [1979] STC 205 stated that it is entirely a matter for the Commissioners’ discretion whether we allow a retrospective application or not.

The fact that a period of retrospection has been allowed does not affect the ninety day period that we have in which to make enquiries into the application. If we do decide to refuse the application it will be annulled with effect from the retrospective date on which it was originally given effect.