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Posted Thu, 12 Oct 2023 22:11:03 GMT by
HMRC guidelines state that if the net VAT impact of errors in outputs/inputs is under 10K or between 10-50k and less than 1% of the value in box 6. The errors can be reported in the return in the period in which they are discovered, otherwise, a VAT 652 submission needs to be done. My question is this: when an entity has a global processing operation, whereby the scanning centre for its invoices is in one jurisdiction and the accounting in another, this can lead to a time delay from when the invoice is issued, received, scanned and processed for accounting. Consequently, there will be a significant amount of invoices that may not get processed in correct VAT period (if we consider it by the invoice date), hence the posting date and document date (i.e. the invoice date/default tax point) are different. For example, towards the end of Q1 there could be volumes of invoices that arrive with a document date of 30th March, but these may not get processed and posted until 10th April. Sometimes even 2 or 3 invoices could breach the 50k threshold. if this is something that is happening on a regular basis, due to the nature of the business and its global processes, does the business have the flexibility to prepare the VAT returns based on the posting date and not the document date? Otherwise, a VAT 652 would be required every quarter, which would not be feasible and practically not make sense. Please advise if there is any flexibility here.
Posted Tue, 17 Oct 2023 11:25:45 GMT by HMRC Admin 8 Response
Hi,
A business must normally account for VAT on the VAT return for the tax period in which the tax point occurs, at the rate in force at that time.
But, if you use the Cash Accounting Scheme this may be different. For more information on the special rules for this scheme read Cash accounting (VAT Notice 731).
For guidance on tax points please refer to notice 700 section 14
Time of supply (tax point) rules
If your current system is not enabling you to be able to meet the VAT record keeping requirements, then that is something you would need to look at adjusting and whether there is a better electronic system your software provider may be able to assist you with.
Guidance on keeping VAT records and be found here:
Record keeping (VAT Notice 700/21)
Thank you.
 
Posted Tue, 17 Oct 2023 12:37:16 GMT by
Thank you for your response. The issue just to add is the fact that there are large volumes of invoices, that are for example sent by suppliers towards the end of a VAT quarter end period, and it could take up to 10 days to scan, process and post them in the system. We therefore a posting date (date posted in the system), and a document date (invoice date). When we run our reports by posting date and then prepare the VAT return on the VAT transactions by document date, and anything that has been posted in the VAT quarter with a document date prior to the quarter, we would apply the VAT corrections criteria, i.e. less than 10k or between 10 and 50K and 1% of box 6, or above 50K. This allows us to assess whether or not a VAT 652 is required or not. Please advise if this is the correct approach? Because this can be a regular occurrence, due to the size of the business, and volume of transactions, please advise if there is an alternative, from HMRC's side. The Cash Accounting Scheme would not apply as the VAT taxable turnover would be above the threshold.
Posted Wed, 18 Oct 2023 07:20:33 GMT by HMRC Admin 25 Response
Hi A Taxman,
 A business must normally account for VAT on the VAT return for the tax period in which the tax point occurs, at the rate in force at that time. 
For this reason I can only recommend completing a VAT 652 in the event where the reporting of the invoices is done in a different period to the tax point of the invoice.
There is no alternative for this unfortunately as we need the VAT return to reflect accurately the supplies and purchases falling within the period.
Thank you. 

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