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HMRC internal manual

VAT Small and Medium Enterprises Assurance Manual

Check on registered particulars: notifiable changes

If notifiable changes as defined in Notice 700 - The VAT Guide Para 26.3 in the business have occurred since VAT 1 was completed, but have not been notified, you should ask the trader for a letter confirming the revised particulars. When necessary you should obtain a new VAT 1 and/or VAT 2 as appropriate. The details should be recorded on EF and the relevant paperwork (VAT 12) should be forwarded to the NRS for action under V1-28 Registration.

It is important, for both security and accuracy, that notification is obtained in writing where there is a change to;

  • a trader’s name;
  • a trader’s address or the address of the principal place at which the business is carried on;
  • repayment status;
  • the composition of a partnership, even if one or more of the former partners remains in the partnership;
  • status of the business from limited liability to unlimited liability, or vice versa;
  • bank account number;
  • bank sorting code; and/or
  • girobank number.

A written request should also be obtained to change a return stagger to coincide with a financial year-end.

If written confirmation cannot be obtained during the visit, details should be advised to the VRU for this to be pursued and the directions V1-28 Registration paragraph 14.16 should be followed. The trader is entitled to know the likely consequences of this failure.

It is especially important that verbal notifications of partnership changes are recorded. The Partnership Act 1890, Section 36 requires a change in partnership to be notified for the purpose of establishing the liability of a partner, but does not specify that this has to be in writing.

Certain partnership changes do not involve amendment of the VAT register, therefore we cannot insist on written confirmation under the VAT Regulations 1995 (see V1-28 Registration Table 34). However, such changes do have assessment and debt management implications.

It is essential that all partnership changes notified verbally during a visit should be recorded in EF and, where it is not possible to obtain written confirmation, contact the appropriate Registration Unit, and any written notification required but not obtained during the visit will be pursued.

The officer should check that a repayment trader is still eligible for repayment status, as described in VSME21000. Where, a change of trading activities results in a trader moving from payment to repayment status, written confirmation of the change of activities and request to make monthly returns, should be obtained from the trader to support the setting of the repayment indicator.