Hogan Lovells

Key Dates

The Value Added Tax (Finance) (EU Exit) Order 2019/43 due to come into force on 29 March 2019 but subsequently revoked.

The Value Added Tax (Finance) (EU Exit) (Revocation) Order 2019/1014 in force on 8 July 2019.


The government has made regulations to remove inconsistencies between EU and UK law concerning the VAT treatment of the management of defined contribution (DC) pension funds. 

The 2019/43 regulations created a VAT exemption for management of a "recognised pension fund", defined as a pension fund which:
• is funded solely by or on behalf of pension members;
• the  pension members bear the investment risk;
• the fund contains the pooled contributions of more than one pension member; and
• the risk borne by members is spread over a range of investments.

The 2019/43 regulations were due to have effect from 29 March 2019 but were subsequently revoked by the 2019/1014 regulations following the postponement of Brexit.  The government intends to make further regulations to bring the same changes into effect from a specified date (potentially, 1 April 2020).

Date Accessed: 28/05/2022