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HMRC internal manual

VAT Registration

HM Revenue & Customs
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Transfers of going concerns (TOGC): failure to observe record-keeping obligations


  • the records have not been transferred to the transferee, and
  • the transferee has no details of the transferor’s previous turnover

you should write to the transferee, asking them to obtain the necessary records.

If the records are not produced, you may approach the transferor directly to obtain the information. If the information results in the transferee being liable to register, or to register from an earlier date, you must take action to amend the EDR. Obviously, we would disclose details of this turnover to the transferee. Whilst this is, strictly speaking, information confidential to the transferor, the Solicitor’s office advises that, under the Commissioners’ general powers of care and management of the tax, we would have the authority to disclose it.

It is important to remember that any information disclosed must be only that used by the Commissioners in calculating the transferee’s liability to register.