HMRC moves overseas VAT claims off SDES to file transfer

HMRC has replaced the Secure Data Exchange Service as the electronic route for overseas VAT repayment claims.GOV Businesses established outside the UK claiming UK VAT under Notice 723A now submit electronically through the Transfer files securely with HMRC serviceGOV, emailing the Overseas Repayment Unit for information about the serviceGOV. The previous instructions on registering for SDES through the ORU, including putting SDES in the subject line, confirming business-tax-account status, the 15-day registration contact and the warning not to call the VAT helpline, have been deleted; the notice now simply says to email the ORU for information about the serviceGOV. The service itself was formerly known as SDES: HMRC contacts users with an invitation to register, and businesses already registered for SDES sign in with their existing details.

The switch removes a timing trap. The old page required claimants not yet registered for SDES to request access by 30 November if they wanted to claim electronically by the 31 December application deadline.GOV That 30 November access date is gone with the SDES registration route.GOV Postal filing remains available but is reframed as the fallback, required only where the claimant does not want to use the file transfer serviceGOV, rather than also where SDES registration was missed. The dated-receipt process continues, but the follow-up subject line changes from SDES Claim to Electronic ClaimGOVGOV, and claimants still attach the date-stamped receipt if there has been no contact six months after submission.

The surrounding rules are unchanged. The scheme covers businesses registered abroad that are not registered, liable or registrable for UK VAT, have no UK establishment and make no UK supplies beyond the stated exceptions, on condition of reciprocal treatment by their home country. Claims run on a prescribed year from 1 July to 30 June, with a minimum of £130 for periods of three months or more and £16 for a full-year or remainder claim, and applications must reach HMRC by 31 December after the prescribed year on a strict first-come basis. Each claim needs the VAT65A form completed electronically with a typed schedule, plus correctly completed invoices or import documents; the first application must also include a certificate of status from the home authority proving business registration, valid for 12 months and covering applications made in that year.

Practical points survive the rewrite. Original hard copies of all claim documents must be kept because HMRC may request them and may reject the claim in whole or part without them, and the notice still asks for email consent, allows agent filing with proper authorisation, and pays refunds within six months of a satisfactory application. The postal address block has been replaced with a link to the postal address, and the notice confirms documents cannot be returned, so proof of posting may still be asked for. The legal basis is section 39 of the Value Added Tax Act 1994 with Parts 20A and XXI of the Value Added Tax Regulations 1995, including the force-of-law provisions for the VAT65A form and the certificate of status.