Recovery of import VAT – HMRC clarification on meaning of owner

19 Mar 2021

Following the Revenue & Customs Briefs 2/19[RM1]  and 15/20[RM2]  about the recovery of import VAT by ‘non-owners’, HMRC have recently extensively updated their VAT manual guidance page VIT13300 including a clarification of the meaning of owner, which may be of importance when deciding incoterms and if the buyer is able to subsequently recover the import VAT:

“It is accepted that, as long as the contract of ownership envisages that title will pass at some future date (usually on payment), title does not need to have passed at that earlier point.”