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HMRC internal manual

VAT Registration

Special considerations for certain registrations: receivers appointed under the Law of Property Act 1925 (LPA)

LPA receivers are appointed under a legal charge and the terms of their appointment are such that they generally act as agents of the mortgagor (the borrower) rather than the mortgagee (the lender), unless any specific contractual arrangements have been made to the contrary.

Unlike an administrative receiver, an LPA receiver’s appointment may only cover certain assets and he may have no control over the remaining assets or affairs of the company.

The receiver should make arrangements for tax to be accounted for under the existing registration of the mortgagor. Where the receiver continues to run the business in the mortgagor’s absence, he remains the agent of the mortgagor: he is not the person making taxable supplies.

Where the original registration has been cancelled, it will be necessary to re-register the trader.