HMRC must agree to register a person from the date of his registration application or such earlier date as may be agreed (VATA 1994, Sch. 1, para. 10, as amended by FA 1997, s. 32; Directive 2006/112, art. 169) where HMRC are satisfied that:

(a)the person has a business establishment in the UK, or his normal place of residence is in the UK; and

(b)he does not make or intend to make taxable supplies within the UK; but

(c)he makes or intends to make:

(a)supplies outside the UK which would be taxable supplies if they were made within the UK (e.g. dutiable goods supplied in a customs warehouse); or

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