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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: partially completed schemes

Where Customs have evidence that a scheme has been implemented (there has been a relevant event) then they can make a direction in anticipation of the conditions for the scheme being met. Clear examples of such evidence would be a lease which, because of an entry scheme, becomes an intra-group lease (even though further rental payments have yet to be made since the relevant event) and an uncompleted purchase contract. A direction cannot be issued in anticipation of the relevant event itself.