Value Added Tax (VAT) is an important consideration for UK eCommerce retailers selling into the European Union. Since Brexit, VAT rules have become less straightforward, and understanding the obligations and processes is crucial to remain compliant and avoid penalties in the EU single market. This guide will cover when your business needs to pay VAT, how to register for EU VAT, the One Stop Shop (IOSS) system, and other considerations.
We’ll also discuss how our Brexit eCommerce solutions can help you navigate these complexities.
Understanding VAT rules
VAT is a consumption tax, and is required whenever your sales to EU consumers exceed €10,000 annually. Before Brexit, UK online businesses benefited from simple VAT arrangements with the EU, but the new landscape necessitates a thorough understanding of the current rules.
Threshold for VAT obligations
The €10,000 threshold applies to total sales across all EU member states. If your sales to EU customers exceed this amount, you must charge VAT at the rate applicable in the customer’s country. This is a significant change from the previous system, where VAT was only due if sales to a specific EU country exceeded its individual VAT threshold.
B2B vs B2C sales
For business-to-business (B2B) transactions, it is typically the customer’s responsibility to account for VAT under the reverse-charge mechanism. However, for business-to-consumer (B2C) sales, the onus is on the supplier to charge and remit VAT to the appropriate EU tax authorities.
Online marketplaces
If you sell through online marketplaces, the responsibility for collecting and remitting VAT often passes to the marketplace itself. This can simplify compliance but requires you to understand the specific VAT rules of each platform you use.
Digital services
For digital services, VAT rules depend on where the supplier is based and the ‘use and enjoyment’ provision. Generally, VAT is due where the consumer resides. The complexity of these rules necessitates careful management to ensure your business remains compliant.
The Import One Stop Shop (IOSS)
The IOSS system was introduced to simplify EU VAT rules for eCommerce businesses selling goods valued at €150 or less to consumers. The IOSS allows you to register in one EU member state and report all your EU sales through a single VAT return. This system can significantly reduce the administrative burden associated with multi-country VAT compliance. IOSS is particularly helpful if you’re a small trader that gets online sales through something like Amazon or eBay.
How to register for IOSS
To use the IOSS, you must register through the UK government’s portal or directly with an EU member state. The process involves providing information about your business and the nature of your sales. Once registered, you can submit a quarterly VAT return detailing your sales to all countries in the EU. This single return simplifies the process of paying VAT across multiple countries with different rules.
How to register to pay VAT
Registering to pay EU VAT involves several steps, whether through the IOSS or directly with each EU country where you sell goods. A good starting point is the UK government guidance on how to register for VAT in the EU.
Using the IOSS
If you choose the IOSS, you will need to:
- Register for the IOSS in one EU state.
- Collect VAT on all eligible sales to EU consumers.
- File a single quarterly VAT return through the IOSS portal.
- Pay the collected VAT to the designated IOSS tax authority, which then distributes the VAT to the respective EU countries.
Direct registration
For businesses not eligible for the IOSS or those preferring direct registration, you must:
- Register for VAT in each EU country where you exceed the €10,000 threshold.
- Collect and remit VAT according to each country’s specific rules.
- File separate VAT returns for each country where you are registered.
Other Brexit complexities
Brexit has introduced additional complexities for UK eCommerce retailers, impacting VAT compliance, customs duties, and overall logistics. Understanding these new challenges is essential for maintaining smooth operations and unexpected costs.
End of low-value consignment relief
One significant change is the end of relief for low-value shipments. Previously, goods valued under €22 were exempt from VAT when entering the EU. Now, all goods entering the EU from non-EU countries, including the UK, are subject to VAT regardless of their value. This change increases the administrative burden and costs for UK eCommerce retailers, as they must now charge VAT on all shipments to EU consumers.
Customs duty and import VAT
With Brexit, customs duty and VAT now apply to goods sold to EU consumers. These additional charges can significantly impact pricing and logistics for UK eCommerce businesses. Customs duty rates vary depending on the type of product and its country of origin, while import Value Added Tax (VAT) is generally charged at the rate applicable in the country of its destination.
Compliance with new VAT regulations
Brexit has necessitated compliance with new VAT regulations for UK businesses. This includes registering for VAT in EU countries where they exceed the distance sales threshold and managing VAT returns in multiple jurisdictions. Businesses must navigate the complexities of different VAT rates and regulations across the entire EU.
Additional documentation and reporting requirements
Online retailers in the UK now face additional documentation and reporting requirements when selling to customers in the EU. This includes:
- Customs declarations – Detailed information about the goods being shipped, including their value, weight, and origin.
- Proof of origin – Documentation providing where the goods were produced, which can impact the applicable customs duty rates.
- VAT invoices – Accurate VAT invoices that comply with the VAT requirements of the destination.
Increased freight costs and delays
Brexit has led to increased costs and potential delays when shipping goods to the EU. Customs checks and the need for additional documentation, such as customs declarations and proof of origin, can slow down shipping. This can result in longer delivery times and higher costs for UK businesses, affecting their competitiveness in the EU market.
Managing VAT fraud risks
The increased complexity of cross-border VAT compliance also raises the risk of fraud. VAT-registered businesses must implement systems to ensure accurate VAT collection and reporting, and to avoid penalties for non-compliance. Partnering with VAT management experts can help reduce these risks and mean your business adheres to EU VAT regulations.
Autofulfil’s Brexit solution for fulfillment from Ireland into the UK
Understanding and complying with EU VAT rules is essential for UK eCommerce retailers selling into the EU. The introduction of the Import One Stop Shop (IOSS) simplifies some aspects of VAT compliance, but the post-Brexit landscape requires an understanding of different VAT rates and VAT registration requirements. Autofulfil’s EU fulfillment solutions provide valuable support in navigating these challenges.
Autofulfil offers a robust Brexit solution by providing fulfillment services from Ireland. We allow UK eCommerce retailers to maintain frictionless international trade with other EU countries. By storing and shipping products from Ireland, your business can mitigate the complexities of cross-border VAT compliance and customs duties. Learn more about our fulfilment services.
Additionally, we partner with VAT management experts to support our clients in navigating the intricate EU VAT regulations. These partnerships ensure your business remains compliant with all VAT rules, and allow you to focus on growing your eCommerce operations.
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