HMRC requires each non-UK VAT group member to claim its UK VAT refund in its own name

What changed in detail

HMRC published Revenue and Customs Brief 8 (2026) on 8 September 2026. It changes how a non-UK business that belongs to a VAT group in its country of establishment claims a refund of UK VAT under the overseas VAT refund scheme.

All non-UK businesses that are members of a VAT group must submit their own claim for any UK VAT they incur. HMRC will no longer accept a claim from the group’s representative member unless that member incurred the VAT itself.

From 1 January 2021 every non-UK VAT group member had to claim through the representative member — which, where that member was itself registered for UK VAT, left the business that incurred the VAT unable to claim at all. The brief describes this as an unintended consequence of the UK’s exit from the EU, and says the change restores the previous position.

As a transitional measure, HMRC will accept claims for VAT incurred in the 2025 to 2026 prescribed year (1 July 2025 to 30 June 2026) from either the group member that incurred the VAT or the representative member; the deadline for that prescribed year is 31 December 2026. HMRC will also review claims for VAT incurred from 1 January 2021 that it rejected because the representative member did not submit them, provided the VAT was not included in a later claim by the representative member. Requests go to the Overseas Repayments Unit and must be made by 31 August 2027.

What it means

The rule itself is a simplification — it restores the pre-Brexit position and reopens refunds that were structurally impossible where the representative member was UK-registered. The work is in the dates. Two deadlines sit on this brief and neither is far off: 31 December 2026 for the 2025 to 2026 prescribed year, and 31 August 2027 for reconsideration of anything refused since January 2021. HMRC says it will not consider requests received after that date.

The reconsideration route is also narrower than it first reads. It reaches only claims refused because the representative member did not submit them, and only where the VAT was never picked up in a later representative-member claim. So the first task is a reconciliation across the group, not a letter — and groups that have changed their representative member since 2021 will find that the hardest part of it.