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HMRC internal manual

VAT Refunds

Unjust enrichment: Reimbursement: Records to be kept

There is clearly a need to keep records so that we can check that the money has been reimbursed and that it has been paid to the right customers. 

Regulation 43E of the VAT Regulations 1995 requires businesses to keep records of any refunds made. However, the records to be kept are basic and only what we would expect any business to keep in the circumstances.

If the claimant’s existing records are capable of showing when a refund has been made, no additional records need be kept. The important point is to ensure that that there is a visible audit trail that we can follow and check.

As far as the amount of interest is concerned, in practice we would want claimants to note the rate(s) of interest used.