delete The Value Added Tax (Margin Schemes and Removal or Export of Goods: VAT-related Payments) (Late Payment Interest and Repayment Interest) (Amendment) Order 2023
This Order amends VAT margin scheme rules to establish interest mechanics for VAT-related payments. It sets the repayment interest start date as 4 months after a claim is made (Article 16A), allows recovery of erroneously-paid repayment interest as late payment interest under conditions A-C (Article 16B), creates netting rules for periods where both late payment interest debts and repayment interest credits exist simultaneously (Article 16C), and applies existing VATA recovery provisions to these VAT-related payments (Article 16D).
This regulation adds procedural complexity to an already burdensome tax system without clear benefit to Britons. The interest and recovery provisions primarily benefit HMRC administrators and tax practitioners rather than ordinary taxpayers. Such technical rules create compliance costs, litigation risk, and uncertainty. The underlying policy goals—preventing unjust enrichment from erroneous payments and managing timing of interest—could be achieved through simpler, more principle-based rules or would naturally resolve without detailed statutory netting provisions. Inherently, this regulation perpetuates the culture of micro-management in tax law that drives up compliance costs for businesses and creates barriers to economic activity.