CH15300 - Record Keeping: How long must records be retained for: VAT: Shorter retention periods

Although the maximum period that records must be retained is 6 years, a VAT registered person may ask for permission to retain their records for a shorter period. The person must apply for this shorter period in writing to the National Advice Service (NAS) or their allocated VAT officer. A table of the types of records and the recommended minimum period you should allow for retention is at CH15400.

Further information on the availability of concessions is set out in Notice 700 The VAT Guide, and Notice 700/21 Keeping VAT Records. You should view a request for a concession sympathetically but you should not grant it automatically.

A shorter retention period must not be specified in any circumstances in which you suspect that avoidance is involved. To do so would be against HMRC’s anti-avoidance strategy.

In granting a concession, you should aim to allow the minimum period of retention in line with the person’s commercial practice that is consistent with effective assurance.

Other factors that you should take into account when considering a request for a concession include

  • Will granting a concession lead to assurance difficulties? What are they?
  • Will the concession help an avoidance scheme?
  • What is the trader’s history? Do they regularly send in their returns on time and pay any tax due on time?
  • Has the trader been subject to an inaccuracy penalty?
  • Will the concession interfere with determining whether suspended penalty conditions have been met?
  • What degree of independent audit assurance is available?
  • If you insisted on the person retaining their records for the maximum period, would it create real storage problems and/or involve undue extra expense?
  • Is the person aware that, without concession, records may be preserved on microfilm, microfiche or by electronic means in line with Notice 700 The VAT Guide? This may solve their storage problems. See also CH13100 and CH13400.
  • Any record that serves more than one purpose must be kept for the longest period required by those purposes, see CH14100.

If you do grant a concession, you should confirm it in writing and note the person’s Electronic Folder (EF) entry.

This guidance is subject to any different requirements set out in a special scheme, see CH12400.