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HMRC internal manual

VAT Transfer of a going concern

HM Revenue & Customs
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Transfers and VAT Groups: value

The value of the supply by and to the representative member is the open market value ofthe assets by virtue of s44 (7) and 44(8). When the assets are being bought from a person unconnected with the group this will usually be the consideration paid. Where the seller is connected to the group, care should be taken to ensure that the value placed on the assets is realistic.

Where VAT is not due on some of the assets, the consideration must be apportioned between those assets on which tax is due and the other assets. This apportionment must be fair and reasonable.