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HMRC internal manual

VAT Single Entity and Disaggregation

Single Entity and Partnerships: what to do when you are satisfied that there is a single legal entity

If then you should
none of the activities is already registered * consider taking action to compulsorily register the single entity.
one or more of the activities is already registered * determine which entity to register * cancel any existing ineligible registrations * check that the EDR is correct * assess for any underdeclarations
the registration is retrospective or the EDR requires amending * consider whether a penalty is due(See the Late Registration guidance at VATREG26000 (External users can find the guidance at



Alternatively, the evidence you have gathered may indicate that the various businesses are operated as separate business entities now, but were not in the past. In such circumstances, you might have to consider


  • treating the businesses as a single business entity for past periods, and
  • issuing a notice of direction under VATA 94 Sch1 para 2 with effect from a current date.