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The Brexit transition period is over, and the rules for moving goods between the UK and the EU are now different.
Some of these changes affect the VAT on goods which export from the UK to the EU. This guide explains what you need to know if your business exports from the UK to the EU.
You can also read our straightforward summary of all the recent VAT changes.
Now that the UK is not under the umbrella of EU rules, goods moving across the UK border are imports or exports.
This changes some of the processes for businesses which send goods from the UK to the EU. There are different rules in place for businesses providing services or digital sales.
Businesses will need a UK EORI number to export goods from the UK. Your EORI (Economic Operator’s Registration and Identification) number identifies the business as having permission to move goods out of the UK.
The export documents must show two EORI numbers:
This means you’ll need the EU EORI numbers of European businesses that you export to. If you’re exporting goods to your branch or warehouse in the EU, you’ll need your own EU EORI number as well as a UK one.
Your buyer must pay customs duties and tax on the goods that you export to them. So that they pay the right amount, the export documents must include commodity codes.
These codes describe what goods you are exporting. You can check which commodity codes to use for classifying goods with the government’s trade tariff checker.
Businesses exporting to the EU must also make customs declarations for the goods they export. There are different options for handling this process, and you can either do it yourself or through an agent.
Check the guidance for making customs declarations.
You might need export licences depending on the goods that you export. There are also rules for how some types of goods are transported.
Check if you need an export licence.
The changes mean that your EU customers will now pay duty and tax on the goods that you export to them. There are also implications for VAT, which we explain in the next section.
These changes affect how much it costs your EU customers to buy from you. You might need to consider what this means for demand, or for your pricing structure.
UK VAT registered businesses should zero-rate the UK VAT on exports they make from the UK to the EU.
UK VAT is only charged on products or services which are for use in the UK. If the goods aren’t for use in the UK, then UK VAT doesn’t apply.
The goods are still taxable, but the UK VAT is zero-rated, which means the rate of UK VAT charged is 0%. You’ll still need to account for zero-rated VAT on exports in your VAT return.
The key point here is UK VAT. Only the UK VAT is zero-rated on exports. The buyer will still need to pay VAT in the country that the goods are used in.
The process for this depends on whether the buyer is a business or a private consumer.
If the buyer is a business, you’ll need to make sure that they are able to act as an importer for the goods. This includes asking for their EU EORI number.
You won’t have to charge them VAT, but the customs invoice must show the value of the goods so they can pay import VAT at their country’s border.
Since the end of the Brexit transition period the UK is no longer part of EU distance selling rules.
Distance selling means you are, quite literally, selling at a distance. Rather than selling in-person, such as in a shop, sales could be made online, or through catalogues.
In the EU, there are processes which help distance sellers deal with VAT when they sell directly to consumers in other EU countries. EU distance selling rules allow them to charge VAT at the other country’s rate, without registering for VAT there.
Instead, the seller reports the VAT when they submit a VAT return in their own country. That is, until they hit the distance selling threshold. When sales reach the distance selling threshold for a particular country, the seller needs to register for VAT in that country.
The UK is no longer part of EU distance selling rules. You can no longer report the VAT on EU distance-sales through your UK VAT return to HMRC.
Yup, even if your sales are less than the distance selling threshold.
If you’re a UK-based business which sells to EU customers, then you have two choices.
You’ll need to register for VAT in the country where you hold the stock. In doing so, you’ll be able to sell to your EU customers under distance-selling rules from there.
And yes, we know, ouch.
If you decide to register for VAT in an EU country, be aware that some countries require you to appoint a special VAT representative. This agent or representative will be directly liable for any unpaid VAT, so they usually ask for some sort of bank guarantee in exchange.
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