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HMRC internal manual

VAT Traders’ Records Manual

HM Revenue & Customs
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Other Invoicing arrangements for particular businesses: Solicitors: Invoicing by solicitors

For reasons of confidentiality, many solicitors invoice their clients with a two-part document. It may take different forms, but usually consists of:

  • a bill section in the upper part showing separate charges for the supply of the solicitor’s professional services and for his expenses. (These are usually described as “disbursements” but not all of them will be disbursements for VAT purposes as defined in Notice 700, The VAT Guide, section 25); and
  • a tear-off VAT invoice in the lower part for the customer to retain as evidence for input tax deduction.

In principle there is no objection to this practice provided that:

  • the bill section cannot be mistaken for a VAT invoice; and
  • the VAT invoice section contains all the details required on a full VAT invoice.

It is important that the bill section should not contain the details required on a VAT invoice, in particular it must not show the supplier’s VAT registration number. Preferably it should include a legend such as “THIS IS NOT A VAT INVOICE”.

If VAT is shown as a separate amount, the rate should not be specified and a clear reference to the accompanying VAT invoice should be made. On the VAT invoice section, the description of the supply should be sufficient to identify it as a solicitor’s professional services.