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HMRC internal manual

VAT Input Tax

Specific issues: pensions provided for the employees of more than one employer

This page of the manual does not apply where employers are members of the same VAT group registration. Group registration is explained in VAT Groups

Some pension funds provide pensions for the employees of several employers. Those employers may have a commercial link or may be entirely separate from each other. Each employer can only treat as input tax that proportion of the management services proper to their own employees when pensions are provided for the employees of several employers.

Management services could be supplied to a fund that acts for entirely separate employers. The supplier may issue a single invoice either to one of the employers or to the trustee. Either may act as paymaster and treat all the VAT on management services as input tax.

Someone acting as paymaster must recharge each of the employers with their share of the costs plus VAT. The paymaster must issue a VAT invoice to each of the respective employers. The employers can treat the tax on those invoices as their input tax.