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Posted Thu, 22 Feb 2024 21:52:11 GMT by matthew servini
Disposal of surface water discharge (rainwater runoff) falls under the definition of "Supplies of sewerage services" in the VAT manual VWASS3000 - Supplies of sewerage services. Background: The Canal and Riverside Trust are adding 20% VAT to the charge for removing surface water runoff. However, Themes Water classifies surface water discharge and all wastewater disposal as zero-rated sewerage services. Canal and Riverside Trust discharge the rainwater through drainage before erupting into a canal (the River Brent) before entering the River Themes. The runoff managed by Themes water is discharged directly into the Themes after the drainage system. One of these organisations is applying an incorrect VAT rating for the service, and I need to know which is correct. The VAT manual states that sewerage and greywater disposal should be zero-rated for VAT. Surface water runoff in some dictionaries is included in the definition of sewage, but not all. Most encyclopedias describe sewerage as carrying away wastewater (including rain runoff) and human waste from houses and other buildings through underground pipes or passages. Every utility company applies a zero rating to removing wastewater, which includes surface runoff in its definition.
Posted Tue, 27 Feb 2024 08:36:19 GMT by HMRC Admin 19 Response
Hi,

You have refered to the VAT Manual VWAS3000 but the information you are quoting does not match the information in tha guidance. The guidance can be found here:

VWASS3000 - Supplies of sewerage services

Thank you.
Posted Tue, 27 Feb 2024 18:11:35 GMT by matthew servini
The VAT manual VWASS300 I have reference is the same as the manual you have shared in your link . Which states: The reception, disposal or treatment of foul water or sewerage against payment of an unmeasured charge, standing charge, other availability charge, or a specific charge, such as by reference to the quantity and/or the nature of the effluent. Is zero rated. Therefore, I don’t understand your response.
Posted Fri, 01 Mar 2024 09:51:29 GMT by HMRC Admin 25 Response
Hi matthew servini,
The guidance in the manual does state that the following is zero rated:
The reception,  disposal or treatment of foul water or sewerage against payment of an unmeasured charge, standing charge, other availability charge, or a specific charge, such as by reference to the quantity and/or the nature of the effluent.
I would recommend asking the water company the reason why they judge that this guidance doesn't apply and depending on their answer we can explore this further.
Thank you. 

 
Posted Thu, 14 Mar 2024 18:03:30 GMT by matthew servini
The Canal and Rivers Trust judge that this guidance (VAT Manual VWASS3000) does not apply, as after the water travels through the sewer (an underground conduit for carrying off drainage water), it enters a canal. The Canal and Rivers Trust provides sewage disposal services. In my opinion, the fact that the sewage is no longer regarded as sewage after reaching the canal has no relevance. The final destination of the sewerage has no bearing on the service provided. If one pays a company to handle waste and the firm converts the waste into a no longer waste product, the service provided does not change.

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