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Partially exempt businesses affected by COVID-19

29 March 2021      Andrea Marshall, Tax Specialist

Update as at 25 March 2021.  Andrea has agreed the following with HMRC, given that most universties will ahve submitted annual adjustments before the RCB was issued:

Option 1

If COVID 19 has not impacted the university and/or subsidiaries, the adjustment that has been made on the January (or April) 2021 VAT return stands and no further action needs to be taken.

Option 2

If COVID 19 has impacted the university and/or subsidiaries, our members:

  1. follow the COVID 19 PESM’s guidance;
  2. carry out a revised calculation;
  3. seek the fast track email approval from HMRC;
  4. (depending on timing) reverse out the PE adjustment made on the January 2021 return on either the April or July 2021 VAT return;
  5. on the same return, include the calculation made under the COVID 19 PESM’s guidance for the 2020 FYE; and
  6. replace the  “provisional” percentages being used for the July 2021 FYE (which will have been based on the annual adjustment made on the January 2021 VAT return) with those arrived at following agreement with HMRC under step 3.

23/3/21

HMRC has issued this Policy paper in RCB 4/21 on temporary alterations to partial exemption methods, where the pandemic has caused distortion. HMRC will be using an accelerated process to make sure coronavirus-related changes to partial exemption methods are considered, and where appropriate, approved swiftly.

Andrea will be discussing this on the call with HMRC tomorrow and will hopefully provide further clarification, given that universities will have probably already carried out their PE annual adjustment on their January VAT return.







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