Tag Archives: vat-zero-rate

VAT: Exports – updated guidance

By   13 October 2026
Zero-rated exports
HRMC has updated its internal guidance VEXP20300 on VAT exports.
This sets out the conditions for zero-rating an export. 
It clarifies the requirements for zero-rating the indirect export of personal goods (The zero-rating applies as long as the goods do not travel in accompanied baggage) and emphasises the stricter evidential requirements for indirect exports.

VAT: Collagen beauty drinks. The Minerva Research Labs Limited case

By   21 September 2026
Latest from the courts
In the Minerva Research Labs Limited v HMRC [2026] UKFTT 1320 (TC) First-Tier Tribunal (FTT) case the issue was whether collagen beauty drinks are standard-rated, or zero-rated as food of a kind used for human consumption. In order to determine the correct VAT treatment, the Tribunal was required to apply a judicial ‘multifactorial test’. This meant assessing the product’s ingredients, appearance, marketing, and function to decide how an ordinary person would view the product.
Background
The appellant produces a range of collagen-based liquid supplements which are targeted at the health of skin, hair, and joints and muscles. The products are packaged in cartons containing small, single-use, mono-dose bottles. 
Minerva initially accounted for output tax on the sale of the product. However, it subsequently submitted an error-correction claim which sought a refund of circa £3.64 million on the basis that the drinks should be zero-rated food. HMRC rejected the claim, prompting Minerva’s appeal.
NB: For VAT purposes, ‘food’ includes drink.
Decision
 
The FTT acknowledged that the products provide nutritional value; supplying a notable percentage of daily protein requirements alongside energy, vitamins, and minerals, but that nutritional density does not automatically equal food. It determined that:
  • the products were held out for sale as liquid beauty products
  • they were purchased for cosmetic and anti-ageing reasons
  • they were not marketed to be eaten instead of a meal, or as a snack
  • the words ‘dose’ and ‘treatment’ appeared marketing and packaging
  • the products were labelled with precautions or warnings (that food would not)
 Consequently, the products were not food and standard rating applied. 
The appeal was therefore dismissed. 
 
Legislation
VAT Act 1994, Schedule 8, Group 1, item 1. Food of a kind used for human consumption. 
Commentary
Another case on what is food. New products seem appear on a daily basis and the products themselves and marketing of the develop at a rapid pace as a result of changes to consumer tastes and health trends. Trying to fit modern foods into 1970s definitions (when VAT was introduced) will always cause absurd, contradictory results.

This case follows on from well-know cases such as: Jaffa Cakes, Mega Marshmallows, Walkers Sensations Poppadoms, Duelfuel Nutrition, and Greggs, sausage rolls as well as flapjacks, brownies and cereal bars. If there is any doubt about whether a ‘food’ product is covered by the zero-rating, we advise that expert advice is sought (we are happy to provide it!)

VAT: EV charging points in new dwellings are zero-rated

By   1 September 2026

HMRC has updated Notice 708 (para 13.8.1) on 26 August 2026 to include electric vehicle charging points in the list of accepted building materials ordinarily incorporated into a building or its site. These installations qualify for zero or reduced VAT rating when supplied alongside eligible construction or conversion services of the construction or conversion of new dwellings. 

It should be noted that this zero/reduced rating only applies to EV charging points as part of residential construction and that standalone equipment sales and public EV charging services have different VAT rules. 

A VAT Did you know?

By   27 August 2026

Orange juice is zero rated. Lemon juice is zero rated. Mix them, and the product is standard rated.

A VAT Did you know?

By   31 July 2026

Scottish snowballs VAT free, but if you buy Swedish snowballs, they are standard rated.

VAT: New zero rate for domestic electricity

By   27 July 2026

The government has announced that the VAT rate for domestic electricity will be reduced from 5% to zero from 1 October 2026 in advance of winter costs.

It is stated that the government  expects that suppliers will pass the VAT reduction on to their customers (including those on fixed tariffs).

The VAT cut, from 5% to 0%, is estimated to reduce  CPI inflation by around 0.10 percentage points and RPI by around 0.14 percentage points.

This action is estimated to cost  around £850 million in 2026-27 on the basis of estimated electricity prices and will be funded by the cancellation of the Digital ID programme.

 

A VAT Did you know?

By   27 May 2026

Salted nuts are standard rated, but packets of nuts which are still in their shells are VAT free.

VAT and charities – updated guidance

By   13 April 2026

HMRC has updated its guidance on How VAT affects charities. This includes details of a new relief from 1 April 2026 for VAT registered businesses donating goods to a charity (Section 5.5).

A VAT-registered business can zero-rate the donation of goods to a charity or its trading subsidiary provided that the goods are to be offered for sale.

From 1 April 2026, businesses do not have to account for VAT when they donate goods to a charity for:

  • onward donation to an individual, another charity or another organisation
  • use in the charity’s non-business activities

Goods may be donated without incurring a VAT charge when:

  • the goods are eligible
  • A business donates goods for an eligible use
  • the goods are donated to a charity which is either registered with the Charity Commission, corresponding regulator (where required) or registered with HMRC for charity tax purposes
  • The donating business holds evidence that eligible goods have been donated to an eligible charity

Before 1 April 2026 businesses were required to account for VAT on a deemed supply when goods forming part of their assets were donated to a charity and input tax had originally been recovered on their purchase.

More on VAT and charities here.

VAT: New, important HMRC guidance for zero-rating exports

By   10 March 2026

HMRC has updated its Notice 703 which explains the conditions for VAT zero-rating exports of goods. It is crucial for a business to have the correct documentation to evidence goods physically moving out of the UK. 

Information on official evidence has been updated in paragraphs 6.2, 7.1 and 7.2 as follows:

  • Para 6.2 Official evidence

Official evidence is an export declaration for the goods submitted to the Customs Declaration Service which has generated a departure confirmation. You will need the Movement Reference Number (MRN) or Declaration Unique Consignment Reference (DUCR) of the declaration. 

  • Para 7.1 Air and sea freight 
  • If you are using commercial transport documents as proof of export for goods exported outside the UK or EU by:
    • air — you must obtain and retain an authenticated basic master airway bill or house air waybill endorsed with the flight prefix and number, and the date and place of departure
    • sea — you must keep one of the copies of the bill of lading or sea waybill along with a note of the export declaration Movement Reference Number (MRN) or Declaration Unique Consignment Reference (DUCR) or, where a shipping company does not issue these, a certificate of shipment (certifying actual shipment) along with a note of the export MRN or DUCR, given by a responsible official of that company.
  • 7.2 Road freight

    The international consignment note provides evidence of the identity of the contracting parties when goods are transferred by road. It is in 3 parts and is completed and signed by the sender of the goods, the carrier and the person receiving the goods. If the international consignment note is used as part of the evidence, it is important that the information is complete and all the details legible. Where the overseas customer arranges for the goods to be collected ex-works the international consignment note alone is not conclusive evidence that the goods in question have left the UK. Read paragraph 6.6 for additional evidence required when making an indirect export.

    Where goods leave through a port using the Goods Vehicle Movement Service, you should retain the Goods Movement Reference of the vehicle for that journey. 

Failure to produce the appropriate and accurate evidence will result in output tax being due on the relevant goods. 

VAT: Composite or separate supplies – The A & D McFarlane case

By   10 March 2026

Latest from the courts

Yet more on composite or separate supplies. As a background to the issue please see previous relevant cases here here here and here. This is the latest the seemingly endless and conflicting series of cases on whether certain supplies are multiple or single. 

In the First-Tier Tribunal case (FTT) of Alan and Diane McFarland the appellants operated a ‘bed and breakfast’ for other people’s cattle.

The issue

The VAT issue was whether there were separate supplies:

  • zero-rated supply of animal food
  • exempt supply of land.

Additionally, the appellant contended that the supply of animal food was a principal supply, and everything else, including the land, was ancillary. 

HMRC took the view that there was a single taxable supply of ‘animal care’ and not separate supplies of exempt stabling and zero-rated feed. It also rejected the claim that the appellant had an exclusive right of occupation over any defined area, noting that there was no agreement conferring such a right with the consequence that this could not be an exempt supply. On the zero-rated animal foodstuffs point; HMRC concluded that the supplies do not qualify for zero-rating as the food provided formed part of the overall service of animal husbandry.

Legislation

  • Exemption: right over land or any licence to occupy land – The VAT Act 1994, Schedule 9, Group 1,  item 1
  • Zero-rating: animal feeding stuffs – The VAT Act 1994, Schedule 8, Group 1, Item 2.

Decision

The FTT found that there was a single standard rated supply of ‘looking after’ cattle. The supply made by the appellant fell squarely within the Levob (Levob Verzekeringen BV [C-41/04]) category, being so closely linked that they form, objectively, a single, indivisible economic supply, which it would be artificial to split. – HMRC notes on Levob here.

The supply was a fully integrated package of services directed towards the rearing and finishing of cattle. This included: daily mixing and provision of feed, management of water and housing, maintenance of handling facilities, statutory record‑keeping, and disease‑control obligations. These activities were inseparable in practice and indispensable for the operation of the recipient’s cattle‑finishing business. Neither the accommodation nor the feed, nor any other individual component, was offered or taken independently. There was a single price for the complete service. There was also a single invoice and a single description of the supply on the invoice. There was no indication on the invoice that both exempt and zero-rated services were being supplied.

The appellant provided a single composite service of animal rearing and management, to which all elements, including accommodation and feed, were merely constituent elements.

The Tribunal also dismissed the alternative argument of the that the supply of food was the principal supply, with all other elements, including accommodation and the wider activities being merely ancillary. The provision of food was not an aim in itself. The food could not sensibly be separated from the accommodation, handling, record-keeping and welfare-related functions that were also performed. It was, therefore, not the principal supply but an integrated component of the single composite supply.

The appeal was consequently dismissed.

Commentary

Yet another case on the perennial composite/single supply issue. This case was relatively straightforward and the outcome was no surprise. It is essential that businesses that potentially deal with agent/principal matters or make supplies at different VAT rates consider their position. Contracts, other documentation and the commercial reality need to be considered. We recommend that in such circumstances a review is carried out specifically to establish the correct VAT position .