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HMRC internal manual

VAT Transfer of a going concern

Common areas of difficulty: Flat rate farmers scheme

As an alternative to VAT registration, a person involved in certain agricultural business may apply for certification as a flat rate farmer. Details on the scheme are in Notice 700/46 “Agricultural flat rate scheme” and guidance is in VATAFRS

As a flat rate farmer is neither VAT registered nor entitled to be registered (by virtue of his certification as a flat rate farmer) he is not a taxable person. This means that where a VAT registered farmer transfers his business as a going concern to a person who has opted to become certified, the conditions of the TOGC provisions are not met, so he must charge VAT as appropriate on the assets being transferred.