Invoicing abroad and the Place of Supply rules: What VAT should I charge?

Invoicing abroad and the Place of Supply rules: What VAT should I charge?

Invoicing abroad
As of 1 January 2021, the UK ceased to be a member of the customs union, and some of the VAT rules changed. VAT rules on EU imports and exports have broadly aligned with those for non-EU imports and exports. If you are not VAT-registered, or you are a VAT-registered business with UK customers only, then your business will be largely unaffected by the changes.
 
If you invoice customers in Northern Ireland, please get in touch with us for more specialised advice.
 
Place of supply
VAT notice 741A details the place of supply rules. There is now no UK VAT levied on goods or services where the place of supply is outside the UK. This does not necessarily mean the buyer will face no VAT in their own country on the "import" and determining the place of supply is not always straightforward.

The place of supply of a qualifying service is the country where that service is treated as being supplied and where it may be liable to VAT. If the supply is in the UK, it is subject to UK VAT. If the supply is in an EU member state or another country, it is said to be ‘outside the scope’ of UK VAT. The place of supply is determined by where the supplier or customer belongs and if they are a business or an ordinary consumer.
 
How do I know where a business or person belongs?
Typically where the person resides is where the place of supply is. If the customer buying from you has no fixed establishment elsewhere in the world, then the place of supply will be the UK, and VAT is due. 
 
Two types of customer
1) Other Businesses; the transactions are from one business to another. These are called B2B supplies. 
2) Consumers are usually ordinary people outside of business. These are called B2C supplies
 
A buyer will be deemed a relevant business person, a B2B, if they are carrying on a business and are not receiving the supply in a personal capacity. The other business does not need to be VAT registered to qualify as a B2B. Where no evidence of being a business is provided, HMRC direct under VATPOSS06500, that the transactions should be treated as B2C.

VAT on services (B2B)
The place of supply rule for business-to-business (B2B) services remains unchanged. UK suppliers should therefore continue to zero-rate their sales to relevant EU customers. As sales B2B outside the UK are outside the scope of VAT, they will not count towards your £90k turnover limit.
 
Example: An IT contractor advises a client in the UK for £10,000 and a client in Dubai for £100,000. What are their VAT obligations?
 
They are not over the VAT threshold of £90,000 as the Dubai client’s sales are outside the scope. If they were voluntarily registered for VAT they would charge 20% on the UK sales and would not charge VAT on the Dubai sales.

VAT on services (B2C)
The place of supply rule for business-to-consumer (B2C) services has changed. Previously, EU customers not VAT-registered were deemed to have the service supplied in the UK and were, therefore, subject to UK VAT. From 1 January 2021, these sales should be zero-rated in line with B2B rules. However, they still count towards your £90,000 VAT threshold. 
 
If your B2C services are not covered by the exemptions in VATPOSS13250, you may need to charge VAT for each EU country separately. You can do this by registering for VAT in each EU member state or registering for the Non-Union MOSS scheme in a single EU state.

VAT on digital sales
Digital services include the supply of audio and visual content for the general public, sales of electronic products such as e-books, games, online documents and website supply. All these items to UK customers are subject to UK VAT. Sales outside the UK are not subject to VAT but may be liable by the country where the individual is based. If you market this via a third-party platform, they will have the responsibility of accounting for the VAT instead of you. 
 
If your services are simply digitally supplied live, such as professional advice or educational courses on Zoom, they are deemed “electronically supplied” and will be covered by the usual rules on services as if you did them in person.

Sales of digital supplies B2C
HMRC guidance on the rules that would apply to digital downloads to B2C state that VAT would be needed to be accounted for on supplies of downloadable material as per the rates of that country that the customer resides in and paid to the Revenue of that country. 

VAT on goods
The place of supply of goods is usually where the goods are physically based or where they are ordinarily dispatched. Supplies will count towards the £90,000 threshold. If your business exports goods to the EU, you must obtain an Economic Operators Registration and Identification number (EORI number). If you already have an EORI number that does not start with GB, you must apply for a new one.
 
From 1 January 2021, all exports to the EU will be zero-rated. However, a tax will be levied by the country receiving (importing) the goods.
 
An ‘importer of record’ must be named in the entry documents. They would need to be registered for VAT in the destination country, pay import VAT and charge this to the customer. In most cases, the customer is expected to be the importer of record.
 
If the customer is the importer of record, they will be liable for the VAT (effectively an additional cost for them). The UK supplier has no liability.
 
If your business imports goods from the EU, please note there will be no £135 minimum exemption threshold from 1 January 2021. The place of supply will be deemed the UK, and therefore a VAT charge will be added for all B2C purchases.
 
For B2B purchases, the reverse charge can still be used if the business customer can provide their VAT registration number.
 
Don’t get caught out by not charging VAT!
Your responsibility is to assess and charge VAT where it is due, not your customer’s responsibility to pay it. This means if you do not charge VAT upon agreeing on a price, you are taking a risk that you will need to pay VAT on the money you have received. If your customer is not VAT registered, they are likely to be unwilling to agree to pay you an extra 20%. 
 
 



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