As noted in V5.213, any arrangements (or proposal for arrangements) are notifiable to HMRC if they pass three tests2:
- Ìý
(1)ÌýÌýÌýÌý they fall within any description prescribed by the Treasury by regulations
- Ìý
(2)ÌýÌýÌýÌý they enable, or might be expected to enable, any person to obtain a tax advantage
- Ìý
(3)ÌýÌýÌýÌý they have a tax advantage as the main benefit (or one of the main benefits)
Tests (2) and (3) are covered above; details of the arrangements ('hallmarked arrangements', or simply 'hallmarks') prescribed by the Treasury are set out below. They fall into two categories: arrangements which apply specifically to VAT, and arrangements which apply generally (ie to any indirect tax).
Arrangements which apply specifically to VAT
Retail supplies—splitting and value shifting3
This hallmark is intended to capture arrangements that split up a supply to a retail customer to benefit from a different VAT treatment for one or more of those split supplies. For example, to quote from HMRC's example in Notice 799, para 7.6.8:
'An operator of a
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Web page updated on 17 Mar 2025 13:25