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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: summary of conditions

Taken together, the conditions require that the relevant event must generate a situation where standard-rated supplies, which have given rise to an input tax credit by any person, are not taxed on their full value, so leading to a tax advantage because input tax deduction is disproportionately greater than the corresponding output tax - essentially the tax advantage of an avoidance scheme such as those described earlier must be present.