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HMRC internal manual

VAT Transfer of a going concern

HM Revenue & Customs
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Transfers and VAT Groups: VAT groups - general

The formation of a VAT group creates a single person for VAT purposes and such any supply by a member of the VAT group is considered to be made by the representative member of the VAT group. Therefore any assets transferred by a VAT group member as part of a TOGC are considered to be transferred by the representative member.

The transfer of assets within a VAT group, like most supplies between the members of a VAT group, is disregarded for VAT purposes under s43(1) VAT Act 1994. Consequently there can be no TOGC of such assets in these circumstances.