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United Kingdom
Key definition
Taxable person definition

What does Taxable person mean? In vat practice, a taxable person is the business or individual that makes taxable supplies and is liable to charge, collect and account for VAT, and to recover input tax, because they are registered or required to register. In the UK (England & Wales, Scotland and Northern Ireland), the term is defined in legislation: under the Value Added Tax Act 1994, s 3(1), a taxable person is a person who is, or is required to be, registered for VAT. It includes individuals, companies, partnerships, VAT groups and non‑established businesses making UK taxable supplies. The status applies for the period during...

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Input tax recovery on UK corporate transactions: business and share acquisitions/sales, restructurings, share issues, holding companies and VAT groups - HMRC guidance and key case law

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Practice notes
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A taxable person may reclaim VAT where it relates to taxable supplies undertaken in the course or advancement of a business. For a general overview of the rules on VAT recovery, refer to Practice Note: When can a person recover VAT? VAT charged on expenses arising in corporate deals, including the professional charges of accountants, solicitors and other advisers, can be recoverable, subject to the facts of the transaction.

This Practice Note examines recovery of VAT on the costs of business disposals and purchases, share disposals and purchases, corporate reorganisations, and share issues. It also addresses the recovery of VAT by holding companies where relevant and appropriate.

For guidance on reclaiming VAT by a UK acquisition group involved in a private equity-backed buyout, see Practice Note: Tax and buyouts—deductibility and VAT recovery of acquisition group deal costs. This Practice Note also cites decisions of the EU Court of Justice.

For material on the continuing relevance of EU law in the UK after the close of the Brexit implementation period on 31 December 2020, see Practice Notes: Retained EU law and tax and Assimilated law and tax...

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Web page updated on 21/05/2026

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