Client account interest and VAT: could separate legal entities help law firms?

David Gage
Written by  David Gage - Partner, VAT
Published on:  29 September 2026

In an earlier article, I examined how interest earned on client money can affect a law firm’s VAT recovery. For firms holding substantial client funds, the resulting restriction can be significant.

We have since explored a further question: could a law firm place its client account in a separate, wholly owned company that provides no legal services, so that the interest is earned outside the main trading firm?

The SRA position makes that simple approach difficult. A subsidiary is a separate legal entity and cannot rely on its parent firm’s authorisation. It would ordinarily need its own SRA authorisation and to provide legal services. There is discretion to depart from the latter requirement where it is in the public interest, but reducing irrecoverable VAT would be unlikely, on its own, to make that case.

That does, however, raise a different possibility

A firm could consider whether legal services that rely heavily on client accounts, such as conveyancing, might genuinely be carried out by a separately authorised entity with its own client account. Other legal services could remain in another entity.

Depending on the facts and the VAT arrangements, this may allow the impact of exempt client account interest on VAT recovery to be more closely aligned with the part of the business that generates it, rather than affecting recovery across the wider firm. It is not an automatic result: the treatment of shared costs, any transactions between the entities and whether they form a VAT group would all need careful consideration.

 

Commercial and regulatory considerations

There is also a commercial and regulatory cost. Each entity would need to operate as a genuine legal services business, with the appropriate authorisation, governance and ongoing compliance. A restructuring would only make sense where the potential VAT benefit justifies those costs and the change works for clients and the firm.

The key point is that VAT cannot be considered in isolation. Firms facing a material cost from client account interest should assess their current recovery position alongside the way their legal services and client accounts are organised. The right answer will depend on the substance of each firm’s arrangements.

To discuss how client account interest affects your firm’s VAT recovery, please contact David Gage or Sandy Cochrane at Gravita.

Similar Insights

A VAT cut may help hospitality, but it is not a silver bullet

5th October 2026
Written by: Sudhir Rawal
The call from more than 800 hospitality businesses for a reduction in VAT from 20% to 10% reflects the growing financial pressures facing one of the UK’s largest employers and most socially important sectors. With...
link to Find Out More

Autumn Budget 2026: What could it mean for VAT and business growth?

30th September 2026
Written by: David Gage
With the 2026 Autumn Budget just around the corner, Britain cannot achieve growth while its tax system rewards people and businesses for doing less. On a medieval estate, the arrangement was clear. The farmer produced...
link to Find Out More

Considerations when importing goods into the UK

27th May 2026
Written by: Ashraf Cuerdo
Importing goods into the UK can be a valuable way to expand your business, strengthen your supply chain and access new markets. However, it may also bring a range of customs, VAT and compliance obligations...
link to Find Out More

Sign up to Gravita's latest updates and newsletters

Stay up-to-date with our event invites, latest news and updates, straight from Gravita's experts.