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HMRC internal manual

VAT Registration

Transfers of going concerns (TOGCs): reallocation of VAT registration number (VAT 68 action): responsibilities of the transferee

  • The transferee takes over responsibility for any tax returns outstanding or tax credits accrued before the transfer.
  • Return declarations made by the transferor are to be treated as having been made by the transferee.
  • The transferee may be assessed for errors made by the transferor prior to the TOGC, including any related interest.
  • The transferee is not liable for any penalty, raised (either before or after the transfer) under VAT Act 1994, sections 59 to 70 for actions by the transferor.
  • The transferee can be liable for any interest due on errors made by the transferor, assessed against the transferee which come to light after the TOGC.