Insights

Offering an ‘early bird’ price discount in return for prompt payment is a common sales tactic used across industry in for example, travel and entertainment, education, memberships and for business products and services. Technically known as PPD (Prompt Payment Discount), its treatment for VAT purposes has changed with effect from 1^st April. If you are either a customer who takes advantage of a PPD offer, or a supplier that issues VAT invoices which offer PPD (or do so in certain situations), it is important to be aware of the changes and the actions required.

In the past, when a PPD offer was made and acted upon within the required timeframe; for example an opportunity to receive a discount of 10% on the full price for payment within 15 days, the supplier would account for the VAT due based on the discounted price offered. This was the case even if the full price was eventually paid. Equally, the buyer had the flexibility of claiming VAT on either the full or discounted price, depending on the way their accounting systems were managed.

Now, with immediate effect, all VAT records must reflect the actual amount paid; suppliers must account for VAT based on the actual amount received and customers may recover the amount of VAT that is actually paid to the supplier. In the case of suppliers, this may involve issuing a credit note to a customer if they declare the full VAT amount in a return but the customer pays at the discounted rate.

Detailed guidance issued by HMRC

Below are full details of the guidance issued by HMRC on complying with the new PPD regulations concerning VAT invoices.

Compliance guidance for suppliers

a) on issuing a VAT invoice, the supplier should enter the invoice into their accounts and record the VAT on the full price. If offering a PPD, the supplier must show the rate of discount offered on the invoice;

b) the supplier may not know if the discount has been taken up until they are paid in accordance with the terms of the PPD offer, or the time limit for the PPD expires;

c) the supplier will need to decide, before they issue an invoice, which of the processes below they will adopt to adjust their accounts in order to record a reduction in consideration where a discount is taken-up;

d) when adjustments take place in a VAT accounting period subsequent to the period in which the supply took place, the method of adjustment needs to comply with Regulation 38 of the VAT Regulations 1995 (SI 1995/2518);

e) the supplier may issue a credit note to evidence the reduction in consideration. In this case, a copy of the credit note must be retained as proof of that reduction;

f) alternatively, if the supplier does not wish to issue a credit note, the invoice must contain the following information (in addition to the normal invoicing requirements):

- the terms of the PPD (PPD terms must include, but need not be limited to, the time by which the discounted price must be paid).

- a statement that the customer can only recover as input tax the VAT paid to the supplier.

Additionally, it might be helpful for invoices to show:

the potentially discounted price;

the VAT on the potentially discounted price; and

the total amount due if the PPD is taken up.

g) if a business has adopted the option at (f) the VAT invoice, containing appropriate wording as described above together with proof of receipt of the discounted price in accordance with the terms of the PPD offer (e.g. a bank statement) will be required to evidence the reduction in consideration, and the reduction to the supplier’s output tax (in accordance with Regulation 38 of the VAT Regulations 1995);

h) HMRC recommends businesses use the following wording on the invoice:

“A discount of X% of the full price applies if payment is made within Y days of the invoice date. No credit note will be issued. Following payment you must ensure you have only recovered the VAT actually paid.”

i) if the discounted price is paid in accordance with the PPD terms, then the supplier must adjust their records to record the output tax on the amount actually received.

If the full amount is received no adjustment will be necessary.

Compliance guidance for customers

On receiving an invoice offering a PPD, a VAT registered customer may recover the VAT charged, in accordance with VAT Regulation 29 of the VAT Regulations 1995.

As adjustments may take place in a VAT accounting period subsequent to the period in which the supply took place, the method of adjustment needs to comply with Regulation 38 of the VAT Regulations 1995 (SI 1995/2518).

In practice this will mean:

a) if the customer pays the full price they record it in their records and no VAT adjustment is necessary;

b) if the customer pays the discounted price in accordance with the PPD terms on receipt of the invoice, they may record the discounted price and VAT on this in their accounts and no subsequent VAT adjustment is necessary;

c) if the customer does not pay when the invoice is first issued, they must record the full price and VAT on the full price in their records as shown on the invoice. If they subsequently decide to take-up the PPD then:

- if they have received an invoice setting out the PPD terms which states no credit note will be issued, they must adjust the VAT in their records when payment is made. They should retain a document that shows the date and amount of payment (e.g. a bank statement) in addition to the invoice to evidence the reduction in consideration;

- if the supplier’s invoice does not state that a credit note will not be issued, the customer must adjust the VAT they claim as input tax when the credit note is received. They must retain the credit note as proof of the reduction in consideration.

Compliance guidance for imports

The legislation in relation to prompt payments on imports has not changed; section 21(3) of VATA 1994 still applies.

Compliance guidance for payments outside PPD terms

Where a supplier receives a payment that falls short of the full price but which is not made in accordance with PPD terms it cannot be treated as a PPD. The supplier must account for VAT on the full amount as stated on the invoice. If the amount not paid remains uncollected it will become a bad debt in the normal way. If a price adjustment is agreed later, then adjustment must be made in the normal way e.g. by way of a credit note.

If you would like further advice on VAT compliance either with regard to PPD or other issues, please contact Simon Paterson by emailing sp@rjp.co.uk