VAT65A refunds for overseas businesses

A business established outside the UK that is not registered, and not required or eligible to register, for UK VAT can reclaim UK VAT on business costs by sending form VAT65A to HMRC’s Overseas Repayment Unit. Claims run on a prescribed year from 1 July to 30 June and must reach HMRC by 31 December after that year ends, so VAT incurred between 1 July 2025 and 30 June 2026 must be claimed by 31 December 2026. The rules are in Part XXI of the VAT Regulations 1995 and HMRC’s VAT Notice 723A.

Who can use the VAT65A scheme?

Section 39 of the VAT Act 1994 lets HMRC repay VAT to people carrying on business wholly outside the UK where that VAT would be input tax if they were UK taxable persons. Notice 723A paragraph 2.2 sets two conditions. You must:

• not be registered, liable or eligible to be registered for VAT in the UK, and
• have no place of business or other residence in the UK and make no supplies in the UK, other than transport services related to the international carriage of goods, or supplies where the UK customer pays the VAT.

Your own country must also allow similar concessions to UK businesses for its turnover taxes. HMRC says it will only refuse on this ground where your country has a refund scheme but refuses to let UK businesses use it.

The Isle of Man counts as part of the UK for this purpose. EU businesses reclaiming VAT on goods bought in Northern Ireland use a separate EU electronic route; VAT65A remains the route for their other UK costs, including services.

What VAT can and cannot be reclaimed?

Regulation 186 allows a refund of VAT on supplies made to you in the UK, and on goods you import where no other relief is available, if the VAT would be input tax were you a UK taxable person. Notice 723A paragraph 2.3 lists what is excluded, including:

• goods and services used for non business activities (only the business element of a mixed supply qualifies)
• anything used to make a supply in the UK
• most ordinary business cars, with only 50% of the VAT on hiring or leasing a car for mixed use allowed
• business entertainment, apart from very basic entertainment of overseas customers
• goods and services bought for resale for the direct benefit of travellers, such as hotel accommodation
• anything used to make supplies outside the UK that would be exempt under Schedule 9 to the VAT Act 1994

Regulation 190 adds that VAT blocked from credit under section 25 for a UK business is also not repaid. If you make both taxable and exempt supplies, you can only recover VAT to the extent the costs relate to taxable supplies, under the partial exemption rules. Import VAT can only be claimed by the owner of the goods, and if importing makes you liable to register for UK VAT, you cannot use the scheme at all.

How does the claim year and the deadline work?

Regulation 185 defines the prescribed year as the 12 months beginning on 1 July. Regulation 192 then sets the rules:

Rule	Requirement
Deadline	No later than 6 months after the end of the prescribed year, which Notice 723A states as 31 December
Period covered	Not less than 3 months and not more than 12 months, except that a final claim for the remainder of the year can be shorter
Minimum claim, part year of 3 months or more	£130
Minimum claim, full year or remainder of the year	£16

You can include items missed from earlier claims, provided the VAT was charged in the same prescribed year. HMRC deals with applications on a first come, first served basis and applies the time limit strictly.

If you want to submit electronically through HMRC’s Secure Data Exchange Service (SDES) and are not yet registered for it, you must request access by 30 November to file by the 31 December deadline. HMRC says it will contact you within 15 calendar days of a request. If you miss that window, you must post the claim on or before 31 December, and HMRC may ask for proof of postage.

What goes with the VAT65A form?

Regulation 191 requires the form to be completed in English, with full information and the declaration, and a certificate of status from the official authority in your country. Notice 723A asks for:

1. Form VAT65A, completed electronically. The schedule at question 9 must be typed, not handwritten.
2. A certificate of status showing the authority’s name, address and stamp or identification mark, your business name and address, the nature of your business and your registration number. Form VAT66A can be used. Each certificate is valid for 12 months from issue, and a claim made within that time does not need a new one.
3. Invoices showing an identifying number, the supplier’s name, address and VAT number, your name and address, the goods or services, the date of supply, the cost excluding VAT, the VAT rate and the VAT charged. For supplies of £250 or less including VAT, fewer details are needed.
4. Import evidence, being the VAT copy of the import entry or other customs document.

If invoices are made out in a trading name, the certificate must show it too. A PO Box is not accepted as a business address unless you can show it is where the business is established. Under regulation 191(3), HMRC refuses any document stamped as used in support of an earlier claim, and it cannot return documents sent by post, so keep the originals.

Can an agent make the claim?

Yes. You must authorise the agent first with a power of attorney or a letter of authority, and Notice 723A paragraph 2.14 gives an acceptable form of wording, including who the refund is to be paid to. The agent may need to register with HMRC as a tax adviser. Electronic signatures, including typed names and scanned signatures, are accepted on the VAT65A and the authority, provided the claimant signs with full and informed consent.

When is the refund paid, and what if it is refused?

HMRC aims to pay within 6 months of receiving a satisfactory application, by SWIFT transfer or to a UK bank account, always in sterling. If you hear nothing within 6 months of an SDES claim, email the Overseas Repayment Unit with your receipt.

Regulation 194 treats each claim as a VAT return for the purposes of section 73 of the VAT Act 1994, which means HMRC can assess if a refund turns out to be wrong. An overpayment is normally deducted from your next refund, and penalties can apply to incorrect or false claims.

If a claim is rejected, HMRC gives reasons. You can ask for a review by an officer not previously involved, writing within 30 days of the decision letter, or appeal to the tax tribunal within 30 days.

What does a claim look like?

Illustration only. A software company established outside the UK, with no UK establishment and no UK sales exhibits at a London conference in October 2025. It pays VAT of £2,400 on stand hire and £150 on a client dinner.

• The £2,400 relates to its business outside the UK and is claimable.
• The client dinner is business entertainment and is excluded unless it is of a very basic nature.
• The VAT falls in the prescribed year 1 July 2025 to 30 June 2026. A single claim for that full year has a £16 minimum and must be with HMRC by 31 December 2026.

Had the company sold goods from stock held in the UK, it would have been making UK supplies, and would need to consider VAT registration rather than this scheme.

What mistakes cause claims to fail?

• Missing the 31 December deadline, or leaving SDES registration until after 30 November.
• Forgetting the certificate of status or sending one that has expired or omits the trading name on the invoices.
• Claiming VAT that is not input tax, such as business entertainment or car purchases.
• Using invoices that are not valid VAT invoices. The VAT invoice requirements apply in full.
• Making UK supplies while claiming as an overseas business.

UK businesses claiming the other way, from EU member states, follow the procedure explained in how a UK business reclaims VAT paid in the EU.

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Related Accountapedia entries

• Overseas businesses registering for UK VAT
• Recording credit notes and refunds
• Reclaiming CIS deductions as a limited company
• Getting a refund of overpaid National Insurance
• Opting out of auto enrolment: refunds and tax

Sources

• legislation.gov.uk: Act 1994 c. 23, section 39
• GOV.UK: Refunds of uk vat for non uk businesses or eu vat for uk businesses
• GOV.UK: Claim vat refunds in northern ireland or the eu if youre established i
• legislation.gov.uk: SI 1995/2518, regulation 186
• legislation.gov.uk: SI 1995/2518, regulation 190
• legislation.gov.uk: SI 1995/2518, regulation 185
• legislation.gov.uk: SI 1995/2518, regulation 192
• legislation.gov.uk: SI 1995/2518, regulation 191
• legislation.gov.uk: SI 1995/2518, regulation 194

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 24 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.