The following conditions need to be satisfied in order that a direction to treat persons as one is made validly:

(a)The direction must be served on each of the persons named in it (VATA 1994, Sch. 1, para. 2(3)); and

(b)HMRC must be satisfied on the following matters (VATA 1994, Sch. 1, para. 2(2) as amended by FA 1997, s. 31 in relation to directions made after 18 March 1997). It is HMRC, and not any other person, who must be satisfied on these matters which are as follows:

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