30 Apr 2025

HMRC to investigate VAT grouping used by welfare providers

What is the issue?

UK VAT law exempts the supply of welfare services provided by public bodies, charities and certain regulated bodies. Unlike public bodies, charities and regulated bodies such as ‘residential care’ cannot claim VAT incurred on expenditure when making such supplies.

To level the playing field, charities and regulated bodies implemented a VAT welfare planning structure to recover VAT that would otherwise be irrecoverable under the partial exemption provisions. The structure is effective for welfare services supplied to local authorities, the NHS and where the VAT grouping provisions are used. This structure has been in place for several years and it was usual for a care provider looking to use it to notify HMRC and the CQC pre implementation.

In Revenue & Customs Brief 2(2025), HMRC have confirmed it now views the use of the VAT grouping provisions within the structure to be a form of tax avoidance. HMRC have promised to fully investigate the tax affairs of those who have implemented it. They also confirmed they will categorise such persons as high-risk taxpayers.

Who is impacted by VAT grouping changes?

Charities and regulated bodies that use a non-regulated entity to supply taxable welfare services to public bodies that would otherwise be VAT exempt if supplied directly by the charity or regulated body.

Actions for organisations using VAT grouping

If your organisation has implemented this structure, you must notify HMRC. Given the potential VAT exposure and wider implications, we strongly recommend doing so through a professional adviser.

We would be happy to advise and assist further if requested.

Please get in touch with our team here.

This field is for validation purposes and should be left unchanged.
GDPR permissions

Latest news

Nick Harris in a suit and open necked shirt

Nick Harris and Lucinda Coleman appointed liquidators of Troax Lee Manufacturing Limited

9 April 2026

Read
Audit partner Mike Hall at Bristol harbourside

International audit specialist promoted to partner at our growing Bristol office

9 April 2026

Read
A casual business meeting between three people

Common EMI questions we see in practice

7 April 2026

Read

Selling shares in your company: Understanding the income tax trap 

1 April 2026

Read
A calendar with the last date of the month circled - it has 'pay day' written on it with a smiley face.

Payroll compliance: Navigating upcoming changes and reforms

1 April 2026

Read
Three people in business attire are seated at a desk in an office, reviewing a document together. The person on the left is pointing at the document while the other two look on attentively.

National minimum wage underpayments and how to prevent them

31 March 2026

Read
Six secondary school students sitting in class whilst two students have their hands up to answer a question.

Academies Accounts Direction 2025 to 2026 published

30 March 2026

Read
A group of 10 PKF Francis Clark colleagues posing with a trophy at the black tie Best Workplaces Awards event

We're up to sixth in UK’s Best Large Workplaces 2026 – and remain top-ranked accountancy firm

19 March 2026

Read
Street of terraced houses

How distributions in specie impact capital allowances

17 March 2026

Read
Group of people smiling in office

Director national insurance contributions

16 March 2026

Read

Incentivising your employees with growth shares

13 March 2026

Read
A group of four colleagues having a discussion around a board room table.

Employment related securities year end: what has to be reported?

9 March 2026

Read