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HMRC internal manual

VAT Groups

VAT avoidance - groups of companies statement of practice on the new Schedule 9A VATA 1994: conditions for the issue of a direction under the new Schedule 9A: background

A direction may only be issued where all of the following conditions are present:

  • A relevant event (VGROUPS08270) has occurred which meets conditions which but for the occurrence of that event would not be fulfilled.
  • The conditions qualifying the relevant event are:

that there has been, or will or may be, a standard-rated (or partly standard-rated) supply on which the output tax due falls to be charged otherwise than by reference to its full value; and the charging of VAT at less than full value gives rise or would give rise to a tax advantage.