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HMRC internal manual

VAT Groups

HM Revenue & Customs
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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: full value condition

In the context of these measures (Schedule 9A, paragraph 1(9)), a supply at less than full value (the undercharged supply) means only those supplies which to any extent have been, or will be, disregarded under the VAT Act 1994, section 43 because they arise between VAT group members. Supplies which, although not disregarded under section 43, are less than full value for other reasons, are not covered. Customs could not, for instance, compulsorily group the parties to a lease and lease-back agreement under arrangements that had nothing to do with the operation of an intra-group disregard. This is not to say that other measures would not apply.