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HMRC internal manual

VAT Transfer of a going concern

HM Revenue & Customs
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Introduction: Background: the scope of VAT

Normally, by virtue of s4(1) VAT Act 1994, VAT is chargeable on any supply of goods or services made by a taxable person in the course or furtherance of his business, provided it is a taxable supply. However a transaction will not be a supply for VAT purposes if:

  • there is no consideration (unless there is a deemed supply);
  • it is within the same legal entity; or
  • there is a specific exclusion in the legislation.

The last includes the supply of assets in the Transfer of a business as a Going Concern (TOGC).