NETP - FORM 652 special dispensation

We have a client who has been recognised as being NETP. The client has 3 separate VAT numbers and has been recognised by Amazon as being NETP for the last 2-3 years. We have been advised to complete form 652 for the above. However, this appears to be required for every quarter for each of the VAT numbers. We wish to amalgamate all the workings of the three VAT registered entities and do the entire workings for the period of the last 3 years as one "deemed" group, using consolidated workings. The number of transactions involved are over 150,000 per year, per entity. Has anyone had experience of this before?

Might be a language thing but how can "a client" (indicating a single business) have three separate VAT numbers? So presumably you mean you have a client that has several subsidiaries or associated companies and each of them have their own VAT number. The reason VAT652 requires the declaration to be made per quarter is because HMRC need to calculate the interest and penalties that may be applicable, and that can only be calculated by knowing when the VAT was due to HMRC and when the VAT was paid to HMRC...or if this is a refund, HMRC still prefer the error declaration to be made per quarter because they can then update their records and VAT accounts per quarter/correctly. You cannot submit a VAT652 for different VAT numbers, one VAT652 = one VAT number. If there are genuinely three different VAT numbers then the declaration - be it a refund or payment to HMRC - has to be declared separate for each VAT number. There is no such thing as a "deemed" group, the companies are either in a formal VAT group, where if they were, the three companies would have one VAT number shared across all three companies ...if not a VAT group then each entity must make it's own VAT652 declaration. You could always submit a single period for each VAT number, but then be prepared for HMRC to query this which will only delay the outcome.

Hi. There are 3 separate vat numbers and a voluntery diclosure form (VAT 652) would be specific to a single VAT number and so you would not be able, unfortunately to use a single VAT 652 to cover errors made on 3 separate VAT numbers. Please see the guidance on error corrections: How to correct VAT errors and make adjustments or claims (VAT Notice 700/45)   . Thank you .