CSE3860 | How the conditions are to be interpreted: ‘Directly Necessary’ services: Members partially exempt: How is apportionment to be made? (guidance effective from 15 August 2018)

HMRC will normally accept the CSG member’s partial exemption recovery percentage as a measure of taxable/exempt use provided that the CSG obtains the current year’s calculation from the member concerned and retains it for production to HMRC should verification be required. This means that the CSG must retain sufficient records to show how the recovery figures received from members and the apportionment calculations made, whether it is VAT registered or not.

If CSGs wish to suggest alternative methodologies, HMRC will give them full consideration but must be satisfied that they give a fair and reasonable result.

HMRC reserves the right to refuse the exemption:

• if the relevant records to justify the apportionment used have not been retained:

• in any case of avoidance or abuse.