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HMRC internal manual

VAT Single Entity and Disaggregation

Disaggregation: types of disaggregation

Most disaggregation cases fall into one of three types:

  1. functional (for example, wet sales and catering in a public house)
  2. geographical (that is, the same activity carried out in different locations. For example, a chain of launderettes)
  3. temporal (that is, different persons operating at different times).

Examples of temporal disaggregation include

  • schemes which rely on the incorporation of a succession of companies each of which trades for a limited period until its turnover nears the registration threshold
  • schemes which involve splitting a business between different persons (or combinations thereof), each of whom is alleged to trade on different days of the week or to be responsible for specific activities or ‘lines’.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000) (This content has been withheld because of exemptions in the Freedom of Information Act 2000)