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HMRC internal manual

VAT Registration

Entity to be registered: trusts and pension funds: trustees and pension funds and VAT group treatment

A corporate trustee may be allowed to join a VAT group provided that it fulfils all the conditions for VAT group treatment laid down in the VAT Act 1994, section 43.

If a corporate trustee (who is the sole trustee of a pension fund and is granted unitary treatment in accordance with VATREG12900) is allowed to join a VAT group, its inclusion within the group will be in respect of all its business activities, both beneficial (non-trustee) and fiduciary (trustee).

If a corporate trustee to whom unitary treatment has not been applied joins a VAT group, it will be in respect of his normal business activities only. The business activities carried on by that company, in its capacity as a trustee of any trusts or pension funds, will be accounted for outside the VAT group under their separate registrations.