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HMRC internal manual

VAT Single Entity and Disaggregation

HM Revenue & Customs
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What to do if you have reached a conclusion of disaggregation: the legal entity created by a Notice of Direction

VAT Act 1994, Schedule 1, paragraph 2(7)(f) provides that the single taxable person created by a Notice of Direction is a partnership of the constituent persons for VAT purposes only. The direction does not create a partnership for any other purpose, including those of the Partnership Act 1890. Strictly speaking, the single entity ‘partnership’ created by the issue of a direction is separate and distinct from any genuine partnership which may exist between the same persons.