Buying printed cups for your business: the VAT invoice you need, why a pro-forma invoice is not enough, and what HMRC changed in 2026

GOV.UK says a VAT-registered business can reclaim the VAT on items it buys for use in the business. For a bulk order of printed cups, that claim normally rests on one document, a VAT invoice, and GOV.UK says a delivery note cannot be used for it. This article sets out what the Value Added Tax Regulations 1995 require a supplier to provide, what HMRC's VAT Notice 700 and GOV.UK say about claiming, and what HMRC changed in Notice 700 in May 2026. It is written for a VAT-registered business buying for its own use. Cups bought to give away raise different questions, which our guide to promotional cups as business gifts covers. It is not tax advice.

When a supplier has to give you a VAT invoice

Regulation 13(1) of the Value Added Tax Regulations 1995 says that where a registered person makes a taxable supply in the United Kingdom to a taxable person, it must provide a VAT invoice, save as otherwise provided in the Regulations. Regulation 13(5) sets the time: within 30 days of the time the supply is treated as taking place under section 6 of the Value Added Tax Act 1994, or such longer period as the Commissioners allow.

Notice 700 puts it in the same terms and adds three points. Customers need VAT invoices as evidence for reclaiming the VAT as input tax. A supplier does not have to issue a VAT invoice for zero-rated supplies. And it does not have to issue one to a customer who is not VAT registered, although the Notice says that in practice a supplier will probably issue one to any customer who asks.

What the invoice has to show

Regulation 14(1), save as the Commissioners may otherwise allow, lists the particulars. They are a sequential number that identifies the document, the time of the supply, the date of issue, the supplier's name, address and VAT registration number, the customer's name and address, and a description sufficient to identify the goods. For each description the invoice shows the quantity, the rate of VAT and the amount payable excluding VAT. It also shows the gross total payable excluding VAT, the rate of any cash discount offered, the total VAT chargeable in sterling and the unit price.

Notice 700 repeats the list and says a supplier may invoice under a trading name but must show somewhere the name and address under which it is registered for VAT. On the unit price, it says the requirement applies to countable goods or services, and that the unit price may not need to be shown at all if it is not normally provided in a particular business sector and is not required by the customer. A run of printed cups priced per cup is countable in our reading.

For smaller orders, section 16.6.1 of Notice 700, on the page last updated on 25 June 2026, allows a simplified VAT invoice where the value of the supply is £250 or less and the customer agrees, with a further condition for businesses based in Northern Ireland. It must carry the supplier's name, address and VAT registration number, the time of supply, a description of the goods and, for each VAT rate, the total payable including VAT and the rate.

A quote, a pro-forma invoice and a delivery note

Regulation 29(2)(a) says that a person claiming input tax on a supply from another taxable person must hold the document that regulation 13 requires, which is a VAT invoice.

Notice 700 section 17.3 says pro-forma invoices are often used to offer goods or services to potential customers, and that, used in that way, they cannot be used as evidence to reclaim input tax even if they show all the details required for a VAT invoice. It says they should be clearly marked as not a VAT invoice, and that if the goods or services are then supplied or payment is received, the supplier must issue a proper VAT invoice. Section 19.5.1 says an invoice marked pro-forma, or marked as not a tax invoice, cannot be used as evidence for reclaiming input tax. GOV.UK says the same in one sentence: you cannot reclaim VAT using an invalid invoice, a pro-forma invoice, a statement or a delivery note.

A quotation is not named in these sources. In our reading it offers a price and records no supply, so it cannot stand in for the document regulation 29 asks the buyer to hold.

Paying before delivery, or in stages

A custom print order may be paid for in part or in full before the cups are made. Notice 700 sets out the supplier's side. Where a VAT invoice is issued or a payment is received before the basic tax point, the tax point for the amount invoiced or received is the date of the invoice or the payment, whichever happens first, and most deposits serve primarily as advance payments that create a tax point when they are received (sections 14.2.2 and 14.2.3). A supplier normally issues a VAT invoice within 30 days of a tax point arising (section 16.2.3). In our reading, a buyer paying a deposit or paying in stages should ask for a VAT invoice covering each payment, not only the last one.

Regulation 29(1) deals with timing on the buyer's side: if the buyer does not hold the invoice when it would otherwise make the claim, it claims on the return for the first period in which it holds it. GOV.UK adds two limits. A business that pays less than the amount due on an invoice can only reclaim the VAT on the amount paid, and it cannot claim more VAT than a valid VAT invoice shows. Where a supplier issues an invoice with the wrong amount to pay, GOV.UK says to ask the supplier to correct it and issue a new invoice.

If you do not hold a VAT invoice

HMRC updated Notice 700 on 29 May 2026. The update note says section 16.8, on invalid invoice procedures, was removed, and sections 19.5.3, 19.5.4 and 19.5.5 were added for when you do not hold a VAT invoice.

Section 19.5.3 says the first step is to go back to the supplier and request an invoice that meets the requirements. If the business cannot do that, or the supplier does not provide one and can evidence why, it must satisfy HMRC that the conditions for input tax recovery are met. Those conditions are that there has been a supply of goods or services, that it took place in the UK, that it is taxable at the standard or reduced rate, that the supplier is a taxable person, that the supply was made to the person claiming, that the recipient was a taxable person at the time the VAT was incurred, and that the recipient intends to use the goods or services for business purposes. The business must also hold other evidence that the transaction occurred.

Section 19.5.4 says HMRC can only use its discretion when there is sufficient evidence that a supply has taken place, and that where it is satisfied that the business took reasonable steps to obtain a VAT invoice and that there is no risk of fraud or threat to the revenue, it will consider exercising discretion to accept alternative evidence. Section 19.5.5 applies the same route to an invalid invoice, which needs satisfactory alternative evidence. In our reading these sections describe a discretion that HMRC may exercise, so a buyer who plans around them is relying on HMRC's judgement.

What cannot be reclaimed at all

GOV.UK lists items on which VAT cannot be reclaimed. Two matter for a cup order. A business cannot reclaim VAT on the cost of entertaining or providing hospitality to people it does business with, for which the page gives theatre or sports tickets as examples, or on anything only for personal use. The page does not name cups, and Notice 700/65 on business entertainment was not read, so in our reading cups bought for a customer hospitality event are a question for an accountant before any VAT is claimed. And GOV.UK says a business on the VAT Flat Rate Scheme cannot reclaim the VAT on its purchases, except for certain capital assets above a stated value. It also says organisations that are not registered for VAT, such as a local authority, academy, public body or eligible charity, follow different rules set out in guidance VAT126, which was not read.

On the product side

The wholesale cups page says cups are priced per cup, excluding VAT, that orders start at 50 cups and that larger runs are quoted per order. The terms and conditions page shows the VAT registration number of Branded Cups Ltd, says a quotation states its applicable pricing and conditions, and says online checkout states the total payable. Neither page says when a VAT invoice is issued or what it looks like, so a buyer who needs one can ask for it when requesting a quote. For events and venues that buy reusable stock, the reusable event cups page lists the cups.

Where this stands

This was checked on 26 October 2026. Regulations 13, 14 and 29 show no known outstanding effects, and the 29 May 2026 change is the most recent update to Notice 700 that touches invoices. HMRC revises this guidance from time to time, and a buyer with a large or unusual order should confirm the current position with HMRC or an accountant.