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HMRC review of import VAT deducted as input tax by non-owners

Updated on October 16, 2026

Last updated: 14 October 2026

Can you reclaim import VAT if you don’t own the goods?

Generally no. HMRC’s position is that only the owner of imported goods, who uses them to make taxable supplies, can reclaim import VAT as input tax. Businesses that import goods on behalf of others, such as freight forwarders, toll manufacturers or call-off stock holders that never own the goods, can’t reclaim import VAT just because their name is on the import declaration or they paid the VAT. HMRC confirmed this in Revenue and Customs Brief 2 (2020) after reviewing claims by non-owners.

Why ownership matters

Import VAT is only input tax if the goods are used, or will be used, for the importer’s own taxable business. If you process or store goods for a customer who owns them, your supply is a service to that customer. The goods themselves aren’t used in your business, so the import VAT isn’t yours to recover.

Common situations

Situation Who can reclaim import VAT
You buy goods abroad and import them for resale You, as owner
A UK processor imports a customer’s goods to work on them (toll manufacturing) The owner (the customer), if UK VAT-registered
A freight forwarder pays import VAT for a client The client, as owner
A non-UK business owns goods held in a UK warehouse The non-UK owner, which may need to register for UK VAT
You import goods on consignment and only own them when sold Usually not you until ownership passes

What non-owners should do

  1. Check who owns the goods at import

2. Make sure the owner, or its agent, is the importer on the customs declaration where possible

3. Use postponed VAT accounting in the owner’s name, so the VAT is accounted for and reclaimed on the owner’s return

4. If you’ve paid import VAT that isn’t yours, agree with the owner how it will be repaid, and change future declarations so the owner is the importer

5. Correct any past claims you made as a non-owner, using the error correction rules

Example

A UK packing company imports £50,000 of goods for a US client that keeps ownership. The packer paid £10,000 import VAT and reclaimed it. Under HMRC’s guidance, it isn’t entitled to do so. It corrects the error, and the US client registers for UK VAT so it can account for import VAT through postponed VAT accounting and reclaim it.

Postponed VAT accounting

Since 1 January 2021, VAT-registered importers can use postponed VAT accounting, declaring and reclaiming import VAT on the same return. It removes the cash-flow cost, but it doesn’t change the ownership rule.

Records to keep

  • Contracts showing who owns the goods and when ownership passes
  • Customs declarations and postponed VAT statements
  • Invoices for processing or storage services

Frequently asked questions

Is the person who pays import VAT always entitled to reclaim it?

No, ownership and use in taxable supplies matter.

Can a freight forwarder reclaim import VAT?

Not on clients’ goods.

Does PVA apply to non-owners?

It should be used by the owner as importer.

Can I correct past claims?

Yes, within the 4-year time limit.

Related: VAT on goods from the EU and VAT on purchases from the USA.

Talk to Accotax

Want this handled for you? Our team at Accotax can help with reclaiming import VAT. See our VAT accountants service, or contact us for a free, no-obligation quote.

This page is general guidance based on HMRC rules for the 2026/27 tax year, checked against gov.uk on 14 October 2026. It is not personal advice, so speak to an accountant about your own situation.

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