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HMRC internal manual

VAT Retail schemes guidance

Eligibility and refusal to allow use of a retail scheme: Definition of a retailer for retail scheme purposes

Although the legislation refers to retailers, it does not define the term.

Dictionary definitions are not particularly helpful.

retailer one who sells goods in small quantities (Oxford English Dictionary)
retail the sale of goods individually or in small quantities to consumers (Collins Concise Dictionary)

We therefore use a definition that derives from the regulations and focuses on the impracticality of normal VAT accounting.

Retailers who cannot reasonably be expected to account for VAT in the normal way may use a retail scheme. This is made clear in Notice 727 Retail schemes, which also provides that traders who make both retail and non-retail supplies (such as wholesale or deemed non-supplies such as under the transfer of a going concern (TOGC) provisions) may use a retail scheme in respect of their retail supplies only.