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HMRC internal manual

VAT Transfer of a going concern

HM Revenue & Customs
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Article 5 VAT (Special Provisions) Order 1995:Has there been the transfer of a business or just a sale of assets?: plant and equipment

If the equipment needed to carry on the business is transferred, this is an indication that there is a TOGC. However, if it is not transferred the transaction can still be aTOGC, especially if the purchaser already owns similar equipment and so does not need the purchaser’s.