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

PKF Francis Clark advises Agrova International on £35m acquisition of Sunrise Eggs

18 December 2025

Read
Nick Harris in a suit and open necked shirt

Bristol-based window company Panoramic enters liquidation

17 December 2025

Read
business people sit around a table and one, a man stands talking, they are in a modern office and all wearing smart suits

How to use capital allowances to offset corporation tax

16 December 2025

Read

Restructuring team triumphs at the TRI Awards in London

8 December 2025

Read

Entrepreneurship- changes to tax rules in the 2025 budget 

27 November 2025

Read
A blur of shoppers on a busy high street on a winters day.

VAT, customs duties and indirect taxes changes in the Autumn Budget 2025

27 November 2025

Read
Two men are working in a manufacturing workshop

Budget 2025: what are the main changes to capital allowances?

27 November 2025

Read
A view of Big Ben and the Houses of Parliament from across the river Thames.

What the Budget means for unincorporated businesses

27 November 2025

Read
A pen rests on a printed balance sheet

Budget tax changes affecting property, dividends and savings income

26 November 2025

Read

How do Autumn Budget 2025 announcements impact business owners’ decisions on profit extraction?

26 November 2025

Read
A business woman talks on her mobile phone whilst working at her computer at home.

Autumn Budget Overview 2025

26 November 2025

Read
A team of professionals in a modern office having a meeting around a conference table.

Salary sacrifice and employment tax changes: What employers need to know

26 November 2025

Read