VAT is charged on persons, not on businesses. A sole trader is one person, so every business they run on their own account is covered by a single VAT registration, and the turnover of all those businesses is added together when testing the registration threshold. Once registered, VAT applies to the taxable sales of every one of those businesses, not just the one that pushed the total over the limit.

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Why does HMRC treat all my businesses as one for VAT?

The VAT Act 1994 attaches registration to a “person”. Section 3(1) says a person is a taxable person while they are, or are required to be, registered. HMRC’s VAT Registration Manual explains at VATREG02100 that a sole proprietor is a natural person and that it is the sole proprietor who is the “person”. It follows, as VATREG02200 puts it, that in all cases it is the person rather than the business which is registered, so a trader must take into account all of their business activities.

This principle was confirmed by the High Court in C & E Commissioners v Glassborow [1974] STC 142, which HMRC still cites as the authority on whether one person can hold more than one registration. The answer is no. A sole trader who runs a café, lets out a holiday cottage and sells crafts online is, for VAT purposes, one person making three kinds of supply. The trading names may differ, and the businesses may have separate bank accounts and separate sets of accounts, but none of that creates a separate taxable person.

VATREG08150 adds that sole proprietors are registered in their own name, although they can include their business names or trading styles on the application. The registration is of the individual, with the trading names attached to it.

How is turnover added up for the registration threshold?

The threshold test looks at taxable turnover, which VATREG02300 defines as the total value of taxable supplies made by a person in the course or furtherance of business, excluding VAT (VAT Act 1994, section 19). For a sole trader, that means adding together the taxable sales of every business they run. Standard rated, reduced rated and zero rated sales all count. Exempt and out of scope income does not.

For 2026 to 2027 the registration threshold is £90,000. You must register if your total taxable turnover for the last 12 months goes over £90,000, or if you expect it to go over £90,000 in the next 30 days alone. The rolling 12 month test is applied at the end of each month, so a sole trader with several small businesses needs to total all of them each month, not look at each business in isolation. Our page on the VAT registration threshold covers the timing rules in more detail.

Only supplies made in the course or furtherance of a business count. A genuine hobby that is not a business is outside the calculation, but an activity that is run on a regular, commercial basis will usually be a business even if it is small.

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Can you show how the combined test works?

Illustration only. Sam is a self employed electrician with taxable sales of £60,000 in the last 12 months. Sam also runs a small online shop selling refurbished tools, with sales of £35,000 in the same period, all standard rated. Neither business is near the threshold on its own. Together they come to £95,000, which is over £90,000.

Sam is therefore liable to register. Following the gov.uk timing rule, Sam must apply within 30 days of the end of the month in which the total went over the threshold, and the effective date of registration is the first day of the second month after that. From that date Sam must charge VAT on the electrical work and on the tool sales, and can reclaim input tax on the costs of both businesses, subject to the normal rules. One VAT return covers both.

Does a partnership or company I own count as part of my turnover?

No. The single registration rule applies to the same person, and a partnership or company is a different person.

  • Partnerships. Section 45 of the VAT Act 1994 lets a partnership register in the name of the firm. VATREG08750 explains that A carrying on business alone as a sole proprietor is a different person from A carrying on another business in partnership with B, and that a partnership of A, B and C is a different person from a partnership of A, B and D. Each can have its own registration.
  • Companies. A company is a legal person distinct from its shareholders (VATREG02100), so its turnover is not added to the sole trade of the person who owns it.

The flip side is that a partnership is also only allowed one registration, however varied its activities, because the partners acting collectively are a single person. VATREG08750 says a partnership of A, B and C will only be allowed one registration regardless of the diversity of its business activities.

Can I split my business up to stay under the threshold?

Splitting a business between yourself and, for example, your spouse or a company you control does create separate persons on paper. However, HMRC has a statutory power to look through artificial separation. Under Schedule 1, paragraph 2 of the VAT Act 1994, HMRC can issue a notice of direction treating the persons concerned as a single taxable person. VATDSAG05150 sets out the conditions: the person is making taxable supplies, those supplies form part of wider activities carried on with one or more other persons, and the activities taken together give rise to a liability to register.

Paragraph 1A(2) of Schedule 1 requires HMRC to have regard to how closely the persons are bound by financial, economic and organisational links. HMRC does not have to prove an intention to avoid VAT; it has to show that the separation resulted in VAT being avoided. HMRC’s Single Entity and Disaggregation Manual also says a single entity business is one business, even where it has several streams or has been split into components, if it is carried out by a single sole proprietor, partnership or company. In that situation HMRC does not need a direction at all, because there was only ever one person.

The practical point for a sole trader is that moving one activity into a new trading name does nothing. Moving it into a genuinely separate person may work, but only if the new business is run independently in substance, not just in paperwork.

What does one registration mean once I am registered?

  • VAT on everything taxable. Because the person is registered, VAT is due on the taxable supplies of every business they carry on, including a sideline that would never have reached the threshold by itself.
  • One return. All the businesses report through the same VAT returns and the same VAT account. Your records and software need to bring them together, and the Making Tax Digital for VAT rules apply to the whole registration.
  • Exempt activities. VAT Notice 700 (paragraph 13.1) says that if you incur input tax relating to exempt supplies as well as taxable supplies, you are partly exempt and will need a partial exemption method. Because the registration covers the person, an exempt activity in one business can restrict input tax recovery for the registration as a whole. Our guide to VAT partial exemption explains how that works.

What are the common mistakes?

  • Testing each business separately. Monitoring only the main trade and forgetting a side business or occasional online sales is the most frequent reason sole traders register late.
  • Charging VAT on only one business. Once registered, a sole trader who charges VAT on the main trade but not on a second business is under declaring output tax.
  • Applying for a second registration. Starting a new business does not mean a new VAT number. The new activity is covered by the existing registration. Notice 700/1 (paragraph 13.2) asks registered businesses to let HMRC know about any changes that affect their registration details, so update the business activity description if the new trade changes it.
  • Assuming a trading name separates the businesses. It does not, and neither do separate bank accounts or separate accounts.

Late registration exposes the sole trader to VAT on past sales from the date they should have been registered, plus a possible failure to notify penalty. Our page on failure to notify penalties explains how those are worked out.

Where is the law and HMRC guidance?

  • VAT Act 1994, section 3 (taxable persons and registration), section 19 (value of supply) and section 45 (partnerships).
  • VAT Act 1994, Schedule 1, paragraphs 1A and 2 (artificial separation and directions).
  • HMRC VAT Registration Manual, VATREG02100, VATREG02200, VATREG02300, VATREG08150 and VATREG08750.
  • HMRC VAT Single Entity and Disaggregation Manual, VATDSAG03050 and VATDSAG05150.
  • VAT Notice 700/1, Who should register for VAT.

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Sources

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 8 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.