VATREG25200 - Effective Date of Registration (EDR): earlier agreed EDR
The VAT Act 1994, Schedule 1, 5 provides that a trader and the Commissioners may agree an earlier EDR than that required for obligatory registrations. Such requests will usually come from repayment traders, although payment traders may occasionally request such action (possibly prior to the date on which they first made taxable supplies), for example, in order to reclaim input tax on services.
When considering such requests, you should refer to the guidance in VIT32000 which outlines the circumstances in which the trader will be able to reclaim pre-registration input tax. (External users can find this guidance at http://www.hmrc.gov.uk/manuals/vitmanual/VIT32000.htm).
Where the trader is allowed to reclaim this VAT in the normal manner for the period in question, then retrospective registration will not be necessary. Where an earlier agreed date of registration is still appropriate, you should allow requests provided that the inputs:
- relate to the business, and
- would be properly deductible if the trader was registered.