In this article we’ll go over the rules around import and export VAT on cross-border supplies, and what they mean for your business. Jargon ahoy!
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Table of contents
Table of contents
In this article we’ll go over the rules around import and export VAT on cross-border supplies, and what they mean for your business. Jargon ahoy!
VAT is a consumption tax levied on goods and services. In the UK, VAT registered businesses must charge VAT on their taxable sales, and most of us pay VAT on nearly all our purchases.
The principle of how VAT works usually stays the same, but the rules can be confusing when sales cross an international border depending on whether the sale is to a business or a person, involves goods or services, and where it moves to and from.
It wouldn’t be a very helpful article if we left it there, so we’ll go into everything in more detail.
Sales from Great Britain (England, Wales, Scotland) to EU countries are treated pretty much the same as sales to non-EU countries. Having said that, there are still a few things to know! We’ll focus this article on EU and UK VAT rules for now though.
If you sell goods to a VAT-registered business in an EU country, the sale is usually zero-rated for VAT as long as you have the customer’s VAT number and can show evidence of the goods leaving the UK. Your customer will then account for VAT in their own country through the reverse charge mechanism (more on this in a minute).
When selling goods to non-business customers in the EU, VAT rules can vary depending both on the country your customer is in and the value of the goods.
Your options here are either to register for VAT in each EU country you sell to, or register for the One Stop Shop (OSS) scheme in one EU country which would then cover you across the EU.
Goods sold to customers outside the EU are generally zero-rated for VAT, so VAT should not be charged on the sale. You still need to record the transaction correctly in your VAT accounts and keep evidence of the export to explain why you didn’t charge VAT on the sale.
The reverse charge mechanism is a process where the buyer, rather than the seller, accounts for the VAT on a transaction. It’s mostly used in cross-border transactions between VAT registered businesses in order to simplify VAT reporting and prevent tax being paid twice.
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The seller doesn’t charge VAT on the sale, but they will need to include a reference on their invoice which explains the reverse charge will apply. It’s good for the seller because they don’t need to register for VAT in the country they’re selling to.
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The buyer reports the VAT on their VAT return twice: once as an amount they have paid, and once as if they had charged it to a customer. These two entries cancel each other out on the same VAT return, making the transaction VAT-neutral for them. It’s good for the buyer because they don’t need to pay the VAT only to reclaim it later – which is always good news for cash flow!
For businesses selling goods across borders, recording VAT correctly is essential for staying compliant and avoiding penalties. Both of which are extremely good reasons to keep reading, even though VAT and accounting software are rather… dry… subjects.
Here are a few steps to help you through the process.
You’ll need to register for UK VAT if your taxable turnover reaches the UK VAT registration threshold. But be aware that VAT registration rules can vary from one country to the next. Always check what rules are in place for the country you’re selling to
Postponed accounting aims to help UK businesses deal with the impact of import VAT on their cash flow. It’s designed to be helpful, so it’s not mandatory unless you defer your customs declarations.
It means a VAT registered business can import goods from outside the UK, and will just account for the import VAT when they submit their return – rather than paying it upfront at the border and then reclaiming it later.
If you’re selling to another VAT-registered business and need to apply the reverse charge, make sure they’re actually VAT registered. You’ll need their VAT reference number. If you’re dealing with someone in the EU you can verify their registration status using the VAT Information Exchange System (VIES). You’ll need proof of their status for any export documents
For each cross-border sale, decide whether the transaction is subject to the reverse charge, zero-rated, or if VAT needs to be charged. This largely depends on the status of the customer, the destination of the goods, and whether you are using schemes like the OSS for EU sales.
We can’t stress this enough! Yes alright, we make accounting software so we’re a bit precious about record keeping even though it’s very boring, but it doesn’t half make things easier.
Accurate records could include shipping documents, transport records or commercial invoices. You’ll also need to maintain detailed records of all transactions, including customer VAT numbers, how much was charged, on what…
When sending invoices for cross-border sales, make sure they include all the information they should. For zero-rated sales to EU businesses, this includes things like your customer’s VAT number and a statement that the reverse charge applies. For sales under the OSS scheme, your invoices should be based on the VAT rate of the country your customer is in.
Include your cross-border sales in your normal VAT returns. Report zero-rated sales in the relevant boxes, making sure you can back it up with the right documentation. If you are using the OSS scheme, you’ll need to submit a separate quarterly return for your EU sales.
If you’ve waded through everything to get this far, you’ll be delighted to learn the rules around VAT on services can be even more complex than those for goods.
The general rule for charging VAT on services to another business is that you deal with it in the country where your customer is located. This means if you supply services to a business customer in another country, you don’t generally charge UK VAT. Instead, the customer accounts for VAT using the reverse charge mechanism. Hurrah!
For services supplied directly to a consumer, the country from which the service is being supplied is usually where VAT is charged. Again, for most services provided to non-business customers, VAT is charged in the country where the supplier is located. However, there are exceptions, for example with digital services which we’ll look at now.
Recording VAT on cross-border sales for digital services involves identifying where your customers are located and applying the right VAT rate based on their country. For sales to consumers (not businesses) within the EU, you’ll need to charge VAT at the rate that applies in the customer’s country, which can be done through the One Stop Shop scheme.
Keep detailed records of all transactions, including the customer’s location and the amount of VAT charged. This information can then be reported in your VAT return.
UK businesses selling low value goods (generally under £135) to customers abroad need to record VAT differently depending on where the customer is.
For sales to the EU, VAT is charged at the rate of the customer’s country, and the business can use the Import One Stop Shop scheme. For countries outside the EU, VAT is usually zero-rated, but again, you must keep export records as evidence to support this.
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A content writer specialising in business, finance, software, and beyond. I'm a wordsmith with a penchant for puns and making complex subjects accessible.
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