How to register a SIPP or SSAS Pension for VAT

Registering a SIPP or SSAS pension for VAT isn’t as simple as ticking a box — there’s no “pension fund” option on HMRC’s VAT1 form, and the right approach depends on your fund’s trustee structure. This is especially common when a pension invests directly in commercial property, which often brings VAT obligations with it. We break down how SIPP and SSAS VAT registration actually works; which option to select on the VAT1 form; who should be listed as partner;, and what additional forms you may need.

Why would a pension fund need to register for VAT?

If you’ve opened a SIPP or set up a SSAS pension fund it may be necessary to register it for VAT. For example, direct investment in commercial real estate often brings VAT obligations with it and the fund would suffer a material cost if it didn’t register for VAT.

However, “Pension Fund” is not one of the options on the VAT1 form when you apply to HMRC for VAT Registration. So how do you go about it?

The general premise is that the trustees of a pension fund use its assets to make taxable supplies on behalf of the fund. Therefore, the Trustees are required to register on behalf of the fund.

Unfortunately, this still doesn’t lead to one outcome because pension providers have different options on who they include as trustees. Each case depends on the ‘wiring diagram’ underneath the surface and in some scenarios there is a choice over who can register for VAT.

Who registers the pension for VAT — SIPP or SSAS?

SIPP Pensions: Check your provider’s trustee structure

If you’re invested in a SIPP, double check the position with your SIPP provider.  Some providers have set up their SIPP on the basis that their Trustee Company is the sole trustee of the pension fund. If they have registered this Trustee Company for VAT, then they will take care of any VAT administration on behalf of all the SIPPs in their book and there’s little for you to do.

Other SIPP providers take a different approach.  

Either they operate a trustee model where members are also trustees of their SIPPs – in which case each combination of Member(s) + the Trustee Company has to register for VAT separately. Or the provider is ‘sole trustee’ but FCA permissions require them to segregate their fiduciary duties to each beneficiary within separate VAT registrations, rather than using the Trustee Company where member funds are pooled for VAT purposes.

SSAS Pensions: Registering through your trustees

If you have a SSAS it is relatively straightforward: each SSAS has its own trustees who are required to register for VAT on behalf of ‘their’ SSAS. Even if you have a professional SSAS Trustee engaged, they’re not able to operate a ‘sole’ VAT Registration on behalf of the SSAS pensions on their books because the combination of trustees on each fund is always different.

Which option should you choose on the VAT1 form?

If you are required to register your pension fund for VAT, most SIPP/SSAS VAT Registrations utilise a “Partnership” registration.

There is an obvious temptation to tick “Trust” on the form because most SIPP and SSAS are trust based pension funds.  However, the underlying reason for VAT Registration is normally an investment in commercial real estate.  Where land and property are concerned, HMRC policy is to register the Trustees as a Partnership as this follows the approach to joint landowners in other scenarios.

Who Should Be Listed as Partners on Form VAT2?

But the next question is which set of Trustees should be listed as partners?  

Again, this depends on the ‘wiring diagram’ and can also depend on the SIPP Provider/SSAS Administrator’s policy and requirements.  

Most commonly, the trustees of a SSAS will register the Pension Fund itself for VAT.  This means that all member trustees, and the Professional Trustee will be listed on form VAT2 that notifies HMRC which ‘partners’ are party to the VAT Registration.  If a SIPP includes its member(s) as trustees of the fund then they can register for VAT on the same basis.

However, where a group of people hold legal title of a property on trust for a wider group they are also a ‘partnership’ of trustees capable of registering for VAT.  Depending on the policy of a pension provider, it may be this group of people who are party to the VAT registration: this can be particularly apt if a provider requires member trustees to hold legal title on behalf of the pension, so that the Professional Trustee is not listed on Land Registry.

Do You Need to Complete Form VAT5L or Form 1614A Too?

Typically, the application to register for VAT will also have to be accompanied by additional forms.  These include form VAT5L that tells HMRC that your anticipated commercial activity includes land and property. Form 1614A, where you notify Option to Tax on proposed land acquisition, will typically also be required.

How to Register Your Pension for VAT: Next Steps

Start by asking your pension provider as they may cover this all for you, or at least give you the option to have them provide VAT services to your pension.  

If your pension provider does not deal with VAT obligations in-house then it can be worthwhile seeking advice from a specialist. Although it is tempting to file VAT Registration and associated forms yourself, the consequences of making an error on any of the forms can delay property acquisition and even result in VAT loss worth tens of thousands of pounds.

Get Help With SIPP/SSAS VAT Registration

If your normal accountant or tax adviser is not comfortable advising on SIPP/SSAS pensions, contact Iain Harris, Associate Director on 0131 364 4191 or email iain.harris@ae-ca.co.uk. Iain is a tax adviser and VAT specialist for SIPP and SSAS pensions.

The information in this article is for general guidance only and should not be treated as financial, tax, or legal advice. Pension and VAT rules are complex and depend on your individual circumstances — please consult a qualified adviser before registering your SIPP or SSAS for VAT.