HMRC Publish Notice on Direct Mail
HMRC have published a notice on their view of direct mail. It covers issues such as when the transitional arrangements will apply which allow printers to use the old (zero rate) rules for supplies up to 1 August 2015. If the printer wishes to use these it must write to HMRC stating they wish to do so by 30 November or they will not be allowed to use them.
I confess to being rather confused by this notification requirement which seems a departure from normal practice. HMRC are presumably allowing the transitional arrangement because suppliers have a good argument that they were not aware of the HMRC policy they should charge VAT on delivered mailings. If this concessionary treatment is appropriate then it is surely because businesses were as a group not aware of the policy, in which case surely this is true regardless of whether a business writes to HMRC. It is interesting to speculate on whether HMRC would have much luck before the courts defending their refusal to apply a concessionary transitional treatment to a business that did not write to them.
I see why HMRC want printers to write to them – its a fishing expedition. But its wrong. That said if you are a printer, unless you really enjoy judicial reviews it might be a good idea to write as requested. If you are a charity then ensure your printer is so notifying.
I suspect that this issue will end up before the VAT tribunal if HMRC do seek to assess for the past.