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

A casual business meeting between three people

Seven financial metrics that show the health of your business in 2026

7 September 2026

Read
Nick Harris in a suit and open necked shirt

Liquidators appointed to biomass boiler specialist BBSM Limited

7 September 2026

Read
Man and women looking at paperwork together in a kitchen

What is payable when surrendering an investment policy?

4 September 2026

Read
A person sitting at a desk, holding a coffee cup in one hand and typing on a laptop with the other. The desk has papers, glasses, and a small potted plant. There are large windows in the background letting in natural light.

Could your property make you UK tax resident?

1 September 2026

Read
People walking along bridge towards Big Ben in London.

What tax changes might John Healey introduce in his Budget on 28 October?

28 August 2026

Read
Two colleagues deep in thought discussing what they see on a laptop

Exceptional circumstances

25 August 2026

Read
A wooden house cut out lies on a desk, on top of a Post-it note inscribed in black marker with 'Stamp Duty Tax' .

SDLT issues for commercial development

21 August 2026

Read
Group of business people in discussions sitting down around a laptop

FRS 102 revenue recognition changes are coming: is your business ready?

20 August 2026

Read

Breaking UK tax residence: what does it mean and why does it matter?

19 August 2026

Read
Warehouse operative using a tablet to manage inventory in a logistics warehouse, surrounded by stocked pallets and shelving, representing supply chain and international trade operations.

Avoid these common pitfalls on the road to export success

18 August 2026

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

Our response to the key elements of the latest SRA consultation

18 August 2026

Read
Two professionals in business attire are having a conversation in an office setting with a world map on the wall behind them. In the background, four other people are seated and engaged in discussion.

Pillar 2: What you need to know before 30 September 2026

18 August 2026

Read