29 March 2019 
Amanda Darley, Head of Operations and Engagement
Somewhat surprisingly, HMRC have confirmed to BUFDG that emailing a file (e.g. a spreadsheet) within a taxpayer organisation can constitute a digital link for MTD. We would caution, however, that you need to be careful how the file is then linked to other records to ensure that the digital 'journey' is not disrupted, and this will partly depend on the data contained in the file (e.g. is it part of the main VAT return back up data, or is it something like partial exemption calculation figures?).
HMRC's response to BUFDG states that they 'can confirm that emailing a file is acceptable as a digital link within a business. The list in section 4.2.1 provides examples to illustrate acceptable digital links, and is not an exhaustive list. When considering digital links there are no forms of link that are only acceptable when used to transmit data to an agent. The acceptability of a digital link will depend on the method of transfer being used and the information being transferred. Additionally the ‘soft landing’ described in 4.2.1.1 will give businesses 12 months from their date of MTD VAT mandation to ensure that their systems have digital links that work correctly. Please note that digital links will need to be in place for their first MTD VAT returns after the soft landing period has expired.'
The full email exchange on this point can be found in this discussion post.
