HMRC Export Repayments Reinforce the Need for Complete Export Evidence

• UK VAT zero-rating for exported goods is conditional on meeting the requirements in VAT Notice 703. Taxpayers must hold evidence showing both that a supply took place and that the goods actually left the United Kingdom. [gov.uk]
• Acceptable evidence can be official customs evidence or appropriate commercial transport evidence. It must be supported by transaction documents such as the customer order, sales invoice, correspondence, dispatch note, proof of payment or acknowledgement of receipt. [gov.uk]
• An invoice or proof that goods reached the overseas customer does not necessarily provide the complete export evidence required by HMRC. Businesses should obtain final customs or transport evidence and connect it to the corresponding zero-rated invoice.

Extended article

HMRC may review export evidence before releasing a VAT repayment, even where the repayment amount is not unusual.

VAT Notice 703 specifies the conditions that must be satisfied for goods exported from Great Britain, or from Northern Ireland to a non-EU destination, to qualify for zero-rating. The conditions have legal status and must be met in full. [gov.uk]

Evidence can be official or commercial. Official evidence will commonly derive from the Customs Declaration Service or confirmation that a transit procedure has been discharged. Commercial evidence can include relevant air waybills, sea waybills, bills of lading or other transport documents. [gov.uk]

Transport evidence must be supported by documentation demonstrating that a genuine supply occurred. The combined evidence should establish that the transaction took place and that the specific goods left the United Kingdom. [gov.uk]

A delivery stamp or receipt in another country can support the evidence package, but businesses should not automatically assume that it replaces the required customs or transport evidence.

Each zero-rated export should therefore have an evidence file connecting the customer order, sales invoice, export declaration, transport document and proof of exit. Missing evidence can place the zero rate at risk and delay repayment claims.

Official external sources: HMRC VAT Notice 703 on exported goods and HMRC internal guidance on acceptable export evidence. [gov.uk], [gov.uk]