Non-UK businesses reclaiming UK VAT: Notice 723A

A business based outside the UK that pays UK VAT, but is not VAT registered here, can claim it back from HMRC on form VAT65A under VAT Notice 723A. Claims run on a year from 1 July to 30 June and must reach HMRC by the following 31 December, so the deadline for VAT incurred from July 2025 to June 2026 is 31 December 2026. HMRC last updated the notice on 30 October 2026.

Who can reclaim UK VAT under Notice 723A?

You can claim if your business is established outside the UK and meets all of these conditions in HMRC’s VAT Notice 723A:

• you are registered as a business in a country outside the UK
• you are not registered, liable or eligible to register for UK VAT
• you have no place of business or other residence in the UK
• you make no supplies in the UK, apart from international transport or supplies where your UK customer accounts for the VAT

HMRC can refuse claims from a country that has a refund scheme but excludes UK businesses. If you make UK supplies and must register, reclaim VAT on your UK VAT return instead; see VAT registration.

What can and cannot be reclaimed?

You can reclaim VAT on goods and services bought in the UK for your business, and import VAT on goods you own, where no import relief applies. You cannot reclaim VAT on:

• goods and services for non-business use
• supplies used to make supplies in the UK
• most business cars (only 50% of the VAT on a car hired or leased for mixed use)
• business entertainment, apart from very basic overseas customer entertainment
• goods or services bought for resale that benefit travellers, such as hotel rooms
• supplies used to make exempt supplies outside the UK

The same basic rules on blocked VAT apply as for UK businesses; see reclaiming VAT on business expenses.

Claim periods, deadlines and minimum amounts

Each claim covers part or all of a prescribed year, which runs from 1 July to 30 June. A claim must cover at least 3 calendar months, unless it covers the last part of the year.

HMRC applies the 31 December deadline strictly and handles claims in date order. Postal claims must be posted by 31 December, and HMRC may ask for proof of posting.

How to make a claim: step by step

1. Get a certificate of status. Your home tax authority issues it, on HMRC’s form VAT66A or an equivalent official document. It must show your business name, address, activity and registration number, and is valid for 12 months.
2. Collect your VAT invoices. Full invoices need the supplier’s VAT number, your name and address, the date, a description, the net cost, the VAT rate and the VAT amount. A simplified invoice is acceptable for supplies of £250 or less including VAT. For imports, you need the import VAT document.
3. Complete form VAT65A electronically. The schedule at question 9 must be typed, not handwritten.
4. Authorise any agent. Use a letter of authority or power of attorney. Since July 2026 the notice says agents may need to register with HMRC as tax advisers; see tax adviser registration.
5. Submit the claim. Send it electronically through HMRC’s Transfer files securely with HMRC service, with the VAT65A, certificate, invoices and supporting papers, or post copies. Keep all originals, because HMRC can ask for them.
6. Wait for the receipt and refund. HMRC sends a dated receipt for electronic claims and aims to pay within 6 months of a satisfactory claim.

HMRC updated section 2.10 of the notice, on electronic claims, on 30 October 2026. If you get no receipt, email HMRC’s Overseas Repayment Unit at newcastle.oru@hmrc.gov.uk with “Electronic Claim” in the subject line. Its phone line, 0300 322 9279 (+44 300 322 9279 from abroad), is for claims already submitted and opens 8:30am to 4pm, Monday to Friday.

What changed for VAT groups in 2026?

Non-UK members of a UK VAT group must now claim in their own name. HMRC’s Revenue and Customs Brief 8 (2026), published on 8 September 2026, says HMRC will no longer accept claims from a representative member unless it incurred the VAT itself.

HMRC calls the rule it applied from 1 January 2021 an unintended consequence of Brexit. The changes are:

• 2025/26 claims (1 July 2025 to 30 June 2026): either the member that incurred the VAT or the representative member can claim, by 31 December 2026.
• Later years: only the member that incurred the VAT can claim.
• Claims listing members: a claim must give the full names of all group members during the claim period.
• Rejected claims: HMRC will review claims for VAT incurred from 1 January 2021 that were refused because the representative member did not submit them, if the VAT was not claimed later. Requests must reach HMRC by 31 August 2027.

To ask for a review, email newcastle.oru@hmrc.gov.uk with the subject “Reconsideration of a previously refused VAT group claim” and the claim details the brief lists. For how groups work, see VAT groups.

What if HMRC rejects your claim?

HMRC explains its reasons in writing. You can ask for a review by an officer not involved before, in writing within 30 days of the decision letter, or appeal to the tribunal within 30 days.

What advisers should do

1. Diary 31 December 2026 for all 2025/26 claims.
2. List non-UK group members and move their future claims into their own names.
3. Search for group claims refused since 2021 and request reviews before 31 August 2027.
4. Check certificates of status are less than 12 months old.

Frequently asked questions

What form do non-UK businesses use to reclaim UK VAT?

Form VAT65A, completed electronically, with a certificate of status from your home tax authority on a first claim.

What is the deadline for reclaiming UK VAT as a non-UK business?

31 December after the end of the prescribed year that runs from 1 July to 30 June. For 2025/26 that is 31 December 2026.

What is the minimum UK VAT refund claim?

£130 for a claim covering 3 months or more but less than a year, and £16 for a full year or the remainder of a year.

How long does HMRC take to pay a non-UK VAT refund?

HMRC aims to pay within 6 months of receiving a satisfactory claim.

Can a VAT group’s representative member claim for non-UK members?

Only for 2025/26 claims made by 31 December 2026. After that, each non-UK member must claim the VAT it incurred in its own name.