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HMRC internal manual

VAT Registration

HM Revenue & Customs
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Voluntary registration: intending traders: requests from an intending trader for retrospective registration

Requests for backdating an EDR in cases of voluntary registration can only be considered at the time of initial application: see VATREG21150.

When you are considering such requests, traders must be able to provide evidence that they would have satisfied us at the time (that is, the earlier date requested) that they had a firm intention to make taxable supplies.

However, this retrospection is restricted to three years before the date the application is received. See also the reference to the case of Gray in VATREG21300.