First, rule out a typing mistake
Copy the number again from the invoice itself, not from an email or your own records. Check the country code and the number of digits: a UK number is GB and 9 digits (some have 12). Then check again. A missing or swapped digit is by far the most common reason a check fails. Our guide to UK and EU VAT number formats shows the layout for each country.
The usual reasons
- The number on the invoice is wrong. The supplier’s template or software has an old or mistyped number.
- The business has deregistered, perhaps because its turnover fell, the business was sold, or it became a company. A business that isn’t registered can’t charge VAT.
- The business has only just registered, or its records are being updated. EU tax authorities update VIES themselves, and the European Commission says only they can correct it (VIES FAQ, question 7).
- The number belongs to a different business. If the check is valid but the name and address don’t match the invoice, treat it as seriously as a number that isn’t registered.
- The number isn’t registered and never was. Charging VAT without being registered is fraud.
What to ask the supplier
Contact the supplier using details you already hold, not the ones on the invoice you’re querying. Ask them to:
- confirm their VAT registration number in writing
- tell you the date they registered, or deregistered, if relevant
- send a corrected VAT invoice if the number was wrong, or a new invoice without VAT if they aren’t registered
For an EU supplier whose number still shows as invalid, the European Commission’s advice is for the supplier to contact its own tax authority to get its record corrected (VIES FAQ, questions 7 and 13).
Paying the invoice in the meantime
You can pay the part of the invoice that isn’t VAT and hold back the VAT until the supplier sorts out the number. Tell them in writing that this is what you are doing and why. If the supplier turns out not to be registered, the VAT was never due, and they should reissue the invoice without it.
If you think a business is charging VAT without being registered, you can report it to HMRC using Report tax fraud or avoidance.
Can you still reclaim the VAT?
If you’re VAT registered, the VAT invoice is your main evidence for reclaiming VAT. HMRC calls it “the primary evidence” for recovering input tax (Notice 700/21, section 3.2). An invoice with an invalid VAT number isn’t a valid VAT invoice, so the VAT on it is at risk.
HMRC can accept other evidence instead, but only in exceptional cases. Its staff guidance says they will look at whether the VAT was really due and charged by the supplier, whether you paid it, and whether you tried to get a proper VAT invoice (VIT31200). Keep a record of your checks and of what you asked the supplier.
The safest course is to get a corrected invoice before you reclaim. If a large amount is involved, speak to an accountant.