HMRC refreshes VAT guidance on recovering input tax for financial exports to the EU

HMRC has updated its transitional guidance on the VAT treatment of specified supplies of finance and insurance services. The substance dates to the Brexit change that extended input tax recovery to EU customers from 11pm on 31 December 2020. This segment walks through what still binds banks, insurers, investment managers and brokers, and what the October 2026 edit actually removed.

• The 13 October 2026 update only removed out-of-date EU Exit Transitional Provisions from the overview; the post-Brexit recovery rules are unchanged.
• Since 11pm on 31 December 2020, the SSO allows input tax recovery on specified supplies to EU customers, via SI 2020/1545 regulations 91 and 92.
• Amended regulation 102(2A) means previously approved PESMs are read in line with the revised SSO, avoiding the need to apply for a new method.
• Insurers may continue using their current VAT accounting approach to determine the tax point for premiums under Section 6 VATA 94.

Executive summary

HMRC has updated its information sheet on the VAT treatment of specified supplies of finance and insurance services. First published on 5 March 2021, the guidance was last updated on 13 October 2026, when out-of-date guidance about Value Added Tax…

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