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VAT before registration: test goods and services separately

A UK business becomes VAT registered with effect from 1 November 2026. Its first return file includes two February 2026 invoices, one for stock still on the shelf and one for advertising. They are the same age but can produce different results. The stock falls within the four-year goods limit, while the advertising falls outside the six-month services limit. Recovery depends on the purchase type, the effective registration date, what is still held and how the purchase relates to taxable business activity.

HMRC toolkit section on purchases before registration, explaining goods still held within four years and services within six months.
HMRC's 2022 input-tax toolkit distinguishes the four-year goods window from the six-month services window. The article applies those limits with current guidance and business-use conditions. HM Revenue & Customs. Contains public sector information licensed under the Open Government Licence v3.0.. Open Government Licence v3.0.

Start with the effective registration date

Measure both time limits from the effective registration date. If registration is backdated, the backdated date is the one that counts, not the day the certificate arrived. Backdating is not just a way to extend a purchase claim, because taxable sales from the earlier date may also need VAT accounted for.

Capital Goods Scheme items, pre-incorporation costs and property option cases have separate rules and fall outside the tests below.

Goods and services follow different tests

Four years and six months are the outer limits, not automatic entitlements. Only VAT attributable to taxable supplies is recoverable, and partial exemption de minimis limits do not apply to pre-registration VAT.

TestGoodsServices
Normal time limitSupplied no more than four years before registrationSupplied no more than six months before registration
Who and whySupplied to the now-registered person for that businessSupplied to that person for that business and its taxable activities
Position at registrationStill held, or incorporated into goods still heldNot related to goods disposed of before registration
Supporting scheduleStock account with quantities, acquisition dates and disposal detailsService account with descriptions and dates

Sources and context, checked :

Used goods can still qualify

Goods do not need to be unused. A fixed asset used before registration does not need an automatic reduction if it remains in business use, although non-business and exempt use restrictions still apply.

Goods fully consumed or sold before registration do not qualify. Goods originally bought wholly privately also do not become recoverable merely because the registered business later uses them.

Sources and context, checked :

A hypothetical first return claim

In this hypothetical, effective registration is 1 November 2026 and the business uses ordinary standard accounting. The same business bought each item for wholly taxable business use, holds acceptable VAT invoices and has no Capital Goods Scheme asset or blocked input VAT.

PurchaseVATResultClaimExclude
Machine acquired May 2024, still in business use£400Within four years£400£0
Stock acquired August 2026, 60% still held and 40% sold before registration£100Claim only the stock still held£60£40
Consultancy supplied August 2026, supporting the ongoing taxable business£100Within six months£100£0
Advertising supplied February 2026£80Outside six months£0£80
Total£680£560£120

Before the first return

The claim goes on the first VAT return, with acceptable VAT evidence retained. For goods, the key record is what remained at the effective date. If the business cannot show which items it still held, a purchase invoice alone cannot support the claim.

Run the tests in this order so that an old receipt is not included simply because it shows VAT.

  • Fix the effective registration date.
  • Separate goods, services and special cases.
  • Trace goods to stock or assets still held, and confirm the business purpose when they were bought.
  • Use supply dates, invoices and stock and service schedules.
  • Restrict private or exempt use and exclude blocked VAT.

Sources and context, checked :

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