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HMRC internal manual

VAT Time of supply

Treatment of supplies affected by a change in VAT: VAT rate or liability: adoption of the special rules

An important feature of the special change of rate rules is that they are optional and adoption is entirely at the discretion of the supplier. A customer cannot insist that a supplier uses the facility. In practice most suppliers whose customers are not VAT registered will use the arrangements if this results in the customer having to pay less VAT.

The change of rate rules cannot be adopted for supplies where the tax point is created by the issue of a self-billed VAT invoice (see VATTOS5225). Section 88(6) of the VAT Act 1994 (see VATTOS2280) also excludes supplies made under the special arrangements for goods sold in satisfaction of a debt.