My client is an independent mortgage advisor, who is not VAT registered. Her turnover is above £85,000 and all of her income is either commission, which is paid by UK lenders, and flat fees received from customers seeking a mortgage. In the last 12 months, £75,000 of her turnover was derived from helping people seeking a mortgage. She is finding the right product for them based on their finances and helping with submitting applications. The remaining £14,000 is earned by directing customers to specific lenders, and my client gets a small commission from the provider if they take out a mortgage with them. Does my client have to VAT register?