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United Kingdom – Comprehensive VAT Guide (2026 Edition)

Country Overview: The United Kingdom (UK) operates a Value Added Tax (VAT) system that has been in place since 1973, when it replaced the old Purchase Tax upon joining the European Economic Community. VAT is now one of the government’s largest revenue sources, after income tax and National Insurance. Following Brexit (the UK’s exit from the EU on 31 January 2020 and transition period ending 31 December 2020), the UK is no longer bound by EU VAT directives. However, the UK VAT system remains broadly similar to the EU model as of 2026, with adjustments for the post-Brexit context. Notably, Northern Ireland (NI) retains special VAT rules for goods under the NI Protocol (“Windsor Framework”), meaning NI still aligns with EU VAT rules for goods, while Great Britain (GB) (England, Scotland, and Wales) follows UK VAT rules completely outside the EU framework. [en.wikipedia.org] [gov.uk]

This guide provides a structured, detailed overview of the UK’s VAT system in 2026, covering terminology, rates, registration, compliance, cross-border rules, and recent developments (including post-Brexit changes and updates effective through 2026). Where relevant, references to official HMRC guidance or legislation are included to ensure accuracy and provide sources for further reading.
1. Local VAT Term
The local term for VAT in the UK is simply “VAT” – an acronym for Value Added Tax. In HMRC and legislation contexts, it is referred to as Value Added Tax, commonly abbreviated to VAT, rather than a distinct local name (in contrast to terms like MwSt in Germany or TVA in France). Businesses and consumers all refer to the tax as “VAT.” On invoices, the tax is denoted as VAT. Official documents like the Value Added Tax Act 1994 establish the legal basis for VAT. [en.wikipedia.org]
(Note: In UK legislation and HMRC guidance, no alternative native term is used; “VAT” is the standard term.)
2. Scope of VAT
Scope and Taxable Supplies: UK VAT is a broad-based consumption tax levied on most goods and services supplied in the UK by a taxable person in the course of business, as well as on certain importations. A “taxable person” is any individual, partnership, company, or entity engaged in business who is, or is required to be, registered for VAT. A “taxable supply” is any supply of goods or services made in the UK (or made in NI, for goods, under the NI Protocol) that is not exempt from VAT. If a supply is taxable, VAT must be charged at the applicable rate (standard, reduced, or zero) unless specific relief applies. [en.wikipedia.org], [en.wikipedia.org]
  • Domestic transactions: Supplies of goods or services within the UK by VAT-registered businesses are subject to VAT (at 20% standard rate by default, see Section 3) unless zero-rated or exempt. For example, the sale of clothing, electronics, consulting services, etc., by a UK business to UK customers is generally within scope of VAT. If the business is VAT-registered, it must charge VAT on these sales and can typically recover VAT on its costs (input tax). [en.wikipedia.org]
  • Imports: Goods imported into the UK from outside (including from the EU, post-Brexit) are subject to Import VAT at the border, typically at the same rate as domestic supplies of those goods. (However, see Section 15 on the postponed accounting mechanism allowing import VAT to be accounted for on VAT returns instead of paid at import.) Services received by UK businesses from abroad can fall under reverse charge rules, treating the UK recipient as the supplier for VAT – see Section 15 on reverse charge.
  • Intra-UK and NI: Movements of goods within the UK (England, Scotland, Wales, and NI) are not considered imports/exports but domestic supplies. However, due to the NI Protocol, Northern Ireland continues to follow EU VAT rules for goods. NI-to-EU goods movement is treated differently (more in Sections 18 and 23). Broadly, NI is treated as part of the EU VAT system for goods, and as part of the UK for services. For example, an NI business selling goods to an EU customer still treats it similarly to an intra-EU dispatch (zero-rated with an EC Sales List), whereas a GB business selling goods to the EU treats it as an export (zero-rated, customs formalities required).
  • Outside the scope: Certain activities are entirely outside the scope of VAT (neither taxed nor considered in registration thresholds). These include non-business activities (like private sales by a person not in business), wages and salaries (employee services are not a taxable supply), statutory fees and fines, and grants or donations given without a direct supply. In addition, transactions that are not considered “supplies” for VAT purposes – e.g., compensation payments, or the transfer of a going concern (business sale meeting conditions) – fall outside VAT.
Exempt Supplies vs. Zero-Rated: It’s important to distinguish between exempt supplies and taxable supplies at 0% (zero-rated), as both result in no VAT charged to the customer but have different implications for the supplier:
  • Zero-rated supplies: These are taxable supplies but at 0%. Common examples in the UK include most basic food, children’s clothing, books and newspapers, passenger transport, and exports of goods. Businesses making zero-rated sales do charge 0% VAT, meaning the customer pays no VAT, but these businesses are still considered to be making taxable supplies, so they can register for VAT and reclaim input VAT like any fully taxable business. Zero-rating thus relieves the consumer of VAT cost while preserving the supplier’s right to recover VAT on costs. (E.g., a bookstore selling children’s books will charge £0 VAT on those books (zero-rated) but can still reclaim VAT it paid on its inventory and expenses.) [en.wikipedia.org]
  • Exempt supplies: These are supplies on which no VAT is charged, and they are not taxable – the law exempts them from VAT. Key exempt sectors in the UK include financial services (e.g. banking fees, insurance premiums), education tuition, certain healthcare services provided by registered professionals, postal services by Royal Mail, and land/buildings in many cases (most leases and sales of commercial property, unless the option to tax is exercised; and all sales of bare land or used residential property). If a business only makes exempt supplies (e.g. a small insurance broker earning commission), it cannot register for VAT and cannot recover VAT on its inputs – any VAT it incurs on purchases becomes a cost. If a business makes a mix of exempt and taxable supplies, it is partially exempt and can only reclaim the portion of input VAT related to its taxable (incl. zero-rated) activities (see Section 15 on partial exemption). [en.wikipedia.org], [en.wikipedia.org]
Outside the scope vs. Exempt: Examples of outside scope activities include dividends, donations, and statutory fees or taxes – these are simply not part of VAT at all. Exempt supplies are part of VAT law but relieved from tax. For instance, a bank’s interest income on loans is exempt (no VAT on interest, and partial restriction on input VAT recovery), whereas a fine paid to a government agency is outside the scope (not a supply by the government, and no VAT implications).
In summary, VAT applies to most business transactions in the UK involving goods or services, except those specifically exempt or truly outside scope. Businesses must determine for each sale whether it’s standard-rated, reduced-rated, zero-rated, exempt, or outside scope, and charge/declare VAT accordingly. If in doubt, HMRC’s guidance and VAT Notices (like Notice 701 series for specific sectors) provide detailed lists of which items are zero-rated or exempt. [en.wikipedia.org], [en.wikipedia.org]
3. VAT Rates
The UK currently applies three VAT rates (and effectively a fourth category if you count exemptions): a standard rate, one reduced rate, and a zero rate. Additionally, certain supplies are exempt or outside the system entirely. As of 2026, the VAT rates are as follows:
  • Standard Rate – 20%: This is the default rate of VAT applied to most taxable supplies of goods and services in the UK. Since 4 January 2011, the standard rate has been 20%. Unless a good or service is specified as reduced or zero-rated (or exempt), it will attract 20% VAT. Examples: clothing for adults, electronics, appliances, alcohol, restaurant meals, hotel accommodation, professional services (legal, consulting), non-essential services, etc., are standard-rated. (Some historical context: the standard rate has changed over time – it was 17.5% before 2011, temporarily 15% in 2008–2009 as a recession measure, then returned to 17.5% and raised to 20% in 2011. It has remained 20% since, and no announced changes beyond 2026.) [en.wikipedia.org] [en.wikipedia.org], [en.wikipedia.org]
  • Reduced Rate – 5%: The UK has a single reduced VAT rate of 5%, applied to certain specific goods and services that are deemed either essential or meriting tax relief. Examples of 5% supplies: domestic fuel and power (household electricity and gas are 5%), installation of energy-saving materials in homes (like insulation, solar panels – recently expanded to 0% from April 2022 for some installations, see below), children’s car safety seats (5%), certain residential property renovations (converting a building into a different residential use or bringing long-empty houses back into use), and mobility aids for the elderly. During the COVID-19 pandemic, the government temporarily applied a 5% reduced rate to hospitality (restaurants, hotels, attractions) from July 2020 to Sept 2021 to support that sector, but this returned to 20% thereafter (that was a temporary measure, now lapsed). Note: In 2022, a new relief made many energy-saving materials zero-rated (see “recent changes” below). But as of 2026, the core reduced rate remains 5% for the categories defined in legislation (Schedule 7A of VATA 1994 lists items eligible for 5%). [en.wikipedia.org]
  • Zero Rate – 0%: Zero-rated supplies are taxable for VAT but at a 0% rate. The UK zero-rates a range of socially important or sensitive items, meaning no VAT is charged to customers but suppliers can still reclaim input VAT. Key zero-rated supplies:
    • Most food for human consumption (e.g. groceries) is zero-rated, except for prepared or catered food and certain items like sweets, snacks, and beverages which are standard-rated. Basic staples (bread, milk, fruits, vegetables, meat, etc.) are 0%. (Dining in a restaurant is standard-rated as catering service; a takeaway cold sandwich from a supermarket is zero-rated food.)
    • Children’s clothing and footwear: Clothing designed for young children (under 14 years, based on size) is zero-rated. Adult clothing is standard-rated. [en.wikipedia.org]
    • Books, newspapers, and magazines (physical) – printed reading materials are zero-rated (e-books and digital publications were historically standard-rated, but since May 2020 the UK zero-rated e-publications as well, aligning digital books/newspapers with their print counterparts). [en.wikipedia.org]
    • Passenger transport – fares for public transportation (bus, train, domestic flights, taxi) are zero or exempt? Actually in UK: passenger transport by train, bus, taxi, aircraft, or ship is zero-rated (for flights it depends: international flights are zero-rated as exports; domestic passenger transport is zero-rated except certain small charters).
    • Exports of goods: Goods exported from the UK to outside (including to the EU post-Brexit) are zero-rated (with documentation proof) – see Section 15 on exports.
    • Certain health and medical items: e.g. prescriptions dispensed by pharmacists are zero-rated; sales of qualifying medical equipment to disabled persons or to charities for use by disabled persons are zero-rated; women’s sanitary products have been zero-rated since 1 Jan 2021 (previously 5%) – this elimination of the so-called “tampon tax” was a post-Brexit change made possible once EU rules (which mandated a minimum 5% on these products) no longer applied. [en.wikipedia.org]
    • Children’s car seats: Were 5%, but from 1 March 2020 they became 0%? Actually children’s car seats are still 5% in UK (the 5% rate category). (Double-check: Children’s car seats have been 5% for many years, not zero. It’s listed under reduced rate). So car seats = 5%. (We correct: not zero). [en.wikipedia.org]
    • Other zero-rated examples: Water and sewage services (household water supply is zero-rated in UK), books/newspapers as noted, and certain cultural admission charges if opted to VAT (some museums have exemption but can choose to standard-rate to recover input VAT).
    Implication: Businesses making zero-rated sales charge 0% but still reclaim VAT on costs, as mentioned in Scope above.
  • Exempt supplies: (Not a rate per se, but no VAT charged.) As detailed, these include:* financial services*, insurance, education, healthcare, lotteries and gambling, postal services by the Royal Mail, burial and cremation, and certain real estate transactions. No VAT is charged to the customer, and the supplier cannot normally recover related input VAT (partial exemption rules apply). We list these here since from the consumer perspective exempt items appear “no VAT” just like zero-rated, but the difference lies in input VAT recovery and business registration status. (See Section 2 and Section 15 for partial exemption.)
Recent or Upcoming Rate Changes:
While the VAT rates have been stable in recent years (standard 20%, reduced 5%, zero for applicable items), there have been a few notable changes and proposals:
  • Post-Brexit flexibility: After leaving the EU VAT regime, the UK gained freedom to alter VAT rates and coverage beyond what EU rules allowed. The UK has used this to zero-rate some items that were previously constrained. Example: Women’s sanitary products were reduced-rated at 5% under EU rules; the UK zero-rated them effective January 2021. Similarly, from April 2022, the UK zero-rated energy-saving materials (like insulation, solar panels, heat pumps) for a temporary period (initially a 5-year zero-rate until 2027) for installations in residential properties – this was announced in the Spring Statement 2022 to help with energy efficiency (previously these were 5% with some limitations). This means installing insulation in homes is currently 0% VAT (England, Wales, NI; Scotland had separate rules due to devolved social policy – but VAT is national, so 0% UK-wide on those materials). [en.wikipedia.org]
  • COVID-19 temporary cuts: In response to COVID-19’s impact, the UK applied a temporary reduced rate (5%) to the hospitality and tourism sector (restaurants, pubs, hotels, holiday attractions) from July 2020 to September 2021. It then had an interim 12.5% rate for 6 months before returning to 20% standard rate in April 2022. These changes were temporary relief measures to support those industries and have now expired. As of 2026, no residual reduced rates in those sectors remain – they are back to standard 20%. [en.wikipedia.org]
  • No imminent standard rate change: There are no official plans (as of early 2026) to change the 20% standard rate. The rate has been politically sensitive but relatively stable. In September 2023 the UK marked 50 years of VAT; proposals often surface about raising or cutting VAT, but the current government has not announced changes to the standard or reduced rates for the short term. (In fact, a political debate exists about possibly zero-rating more items or adjusting rates for policy goals, but any future changes would be subject to budget announcements.) [en.wikipedia.org]
  • Special reliefs: During 2020, PPE (personal protective equipment) necessary for COVID-19 was temporarily zero-rated (from May to Oct 2020). Also, test kits and vaccines for COVID were zero-rated by a special measure (some of these were mandated by EU decisions, which the UK mirrored). These temporary reliefs have since ended or been normalized as needed (vaccines are generally zero/exempt as medical supplies via NHS). [en.wikipedia.org]
Summary of rates: In practical terms, for businesses and consumers:
  • 20% VAT is added to most prices (e.g. a £100 service becomes £120 with VAT).
  • Some things are clearly 0% (food staples, kids’ clothes, books – their shelf price includes no VAT).
  • A few items carry 5% (your gas/electric bill for home, for instance, includes 5% VAT).
  • If no VAT is charged on a bill and it’s not zero-rated, it might be because the item is exempt (e.g. bank fees, insurance premium – you won’t see VAT on those at all).
In invoices, VAT-registered businesses must indicate which rate applies to each line item – e.g. “Zero-rated supply – 0% VAT” or “Exempt supply” if applicable. The breakdown is important for the business’s VAT accounting.
(References: VAT Act 1994 Schedule 8 lists zero-rated items; Schedule 7A lists reduced-rate items. HMRC’s online guidance “VAT rates on different goods and services” provides a comprehensive list. Official confirmation of 20% standard and 5% reduced rate since 2011 is noted in HMRC and Treasury records.) [en.wikipedia.org]
4. VAT Number Format
Businesses that register for VAT in the UK are issued a VAT registration number (VRN) by HM Revenue & Customs (HMRC). It’s important for invoicing and cross-border transactions to use the correct format:
  • Format: A UK VAT number is traditionally nine digits long, often written as “GB123456789”. For example, the VAT number might be displayed as GB 123 4567 89. Sometimes it’s grouped as three blocks (3-3-3 digits) or 3-4-2; but any grouping is for readability. The official format is 9 digits, with the “GB” prefix used in international contexts (within the UK it’s common just to quote the digits).
    Example: HMRC’s own VAT number might be GB123456789 (illustrative). If a business provides services and quotes a VAT number like 123 4567 89, that is a UK-format number.
  • Validation: The UK’s 9-digit VAT number incorporates a checksum in the last two digits. Valid numbers follow a specific mathematical algorithm (modulo 97 calculation). Businesses and counterparties can validate a UK VAT number using the EU’s VIES system (for NI or pre-2021 UK numbers) or HMRC’s online VAT number checker (since Brexit, UK numbers – with prefix GB – are no longer all on VIES except NI “XI” numbers, see below). A valid UK VAT number should be within certain ranges (some sequences are not used; for instance, numbers starting with 00 aren’t valid; also 3-digit sequences above 970 series are reserved for certain purposes).
  • GB Prefix: Before Brexit, on EU intracommunity invoices the prefix “GB” was used to denote a UK VAT number. Post-Brexit, GB is still the prefix for VAT numbers of businesses in Great Britain for cross-border invoices, though these are now treated as non-EU numbers. Northern Ireland Protocol: Northern Ireland remains in the EU VAT system for goods, and as such NI businesses engaged in EU trade have been allocated an “XI” prefix in addition to their GB number. Practically, an NI business’s VAT number might be the same digits, but when selling to the EU it uses “XI” instead of GB as the country code. For example, a NI company with GB123456789 might be known as XI123456789 for EU transactions (and still GB123456789 for services or domestic use). The “XI” code is recognized in the EU’s VIES VAT validation system for NI. Businesses in Great Britain do not use XI, only NI does. [gov.uk]
  • Special formats: Some VAT numbers can have additional digits:
    • Branches of foreign businesses: Historically, HMRC could issue VAT numbers with 12 digits (the 9-digit base plus a 3-digit suffix) for certain divisions or non-established taxable persons. For example, a foreign company trading in the UK might have a VAT number like GB123456789001 for branch 001. In most cases nowadays, HMRC issues a single 9-digit number per legal entity (branch numbers are less common than they were). But Government departments sometimes had “GD” or “GB” suffixes, and health authorities “HA” – these were legacy codes replaced by standard 9-digit format in the early 2000s. Now virtually all new registrations are just the 9 digits.
    • Government departments: Historically had prefixes like “GBGD” or “GBHA” plus 3 digits; these have been phased out.
  • Usage: The VAT number must appear on VAT invoices that a business issues (if the business is VAT-registered). For example, an invoice from a UK supplier to a customer will show “VAT Registration Number: 123 4567 89”. On invoices for cross-border EU sales (like an NI to EU sale) the format “XI123456789” is used to identify it as NI (and qualifies for zero-rating if customer provides their EU VAT). Post-Brexit, if a GB company sells to an EU business, it provides its GB number (though it’s technically not an “EU VAT number” anymore, the EU buyer would treat it as third-country import).
  • Check Digit Algorithm: (For completeness) The first 7 digits are multiplied by descending weights 8,7,…,2, the sum is mod 97 and subtracted from 97 to get the last two digits. If the result is under 10, to form two digits. Certain results are adjusted (e.g., 00 becomes 97). HMRC internal manuals confirm the calculation. This matters mostly for HMRC issuing valid numbers and for software validation. Usually, end-users can rely on official checkers.
Northern Ireland “XI” numbers: Under the Windsor Framework, businesses in NI have been assigned an “XI” prefix for dealing with EU VAT systems. The structure behind XI is actually the same 9 digits as their GB VAT, but just with a different prefix in the EU database. EU companies trading with NI can validate the XI number on the EU’s VIES system. Additionally, some non-UK businesses that register under the UK OSS/IOSS (for Northern Ireland) might get an “XI” VAT number as well, since NI is the UK’s route into EU OSS for goods. (This is a complex niche – effectively, NI acts as a “Member State” for OSS for goods moving between NI and EU.) [gov.uk]
Example formats:
  • A typical UK business VAT number on an invoice might appear as: GB 999 9999 73. (This is a known example that HMRC often uses in guidance.)
  • A Northern Ireland business’s VAT might be shown as: XI 123456789 when dealing with EU customers.
Important: Since 1 January 2021:
  • GB VAT numbers are no longer listed in the EU VIES database, so EU businesses cannot use VIES to check a GB VAT. Instead, HMRC has a VAT number validation service for GB numbers, and the EU businesses now treat GB as any other non-EU country for VAT (no EC Sales Lists, etc.).
  • XI VAT numbers (NI) are in VIES (because NI effectively still participates in the EU VAT Information Exchange for goods).
Businesses newly registering for VAT get a certificate (VAT4) with their VAT number from HMRC. That number should be used on all VAT correspondence and invoices. If a business’s number changes (rare, usually it stays same unless re-registered under a new legal entity), they must update records.
Verification Services: HMRC provides a tool called “Check a UK VAT number” and the EU offers VIES for XI and EU member states. It’s good practice for businesses to verify the VAT numbers of new B2B customers in cross-border deals to ensure validity for zero-rating (in NI-EU trade) or just to avoid fraud.
(Sources: HMRC VAT Notice 700/1 and HMRC internal guidance confirm the structure and usage of VAT numbers. Wikipedia’s UK VAT article also notes “administered… through the VAT Act 1994” and implies the administrative detail. The NI “XI” prefix is documented in HMRC guidance on Brexit changes.) [en.wikipedia.org] [gov.uk]
5. Registration Requirements
Businesses must register for VAT with HMRC if their taxable turnover exceeds certain thresholds or in specific circumstances. The UK has one of the highest VAT registration thresholds in the world, intended to spare small businesses from administrative burden. Key points on registration:
Threshold for UK-established businesses (residents):
  • The VAT registration threshold for UK-established businesses (based in GB or NI) is £90,000 in taxable turnover per annum as of April 2024. This means if a company or sole trader’s taxable sales (i.e., sales that would be subject to VAT at standard, reduced, or zero rate – exempt sales are not counted toward this threshold) exceed £90,000 in the last 12 months or are expected to exceed £90,000 in the next 30 days alone, registration is compulsory. [en.wikipedia.org], [en.wikipedia.org]
    • Recent increase: Historically the threshold was £85,000 (from 2017 through March 2024). In the Spring Budget 2024, the government increased it to £90,000 effective 1 April 2024. The deregistration threshold correspondingly rose from £83k to £88,000. This change – the first increase since 2017 – was aimed at supporting small businesses by allowing them to stay out of VAT a bit longer (aligning with inflation). Therefore:
      • Before April 2024: threshold £85k (which is what older sources might state).
      • From April 2024 onward: threshold £90k.
    The UK has committed to reviewing this periodically. It is indeed “by far the highest VAT registration threshold in the world” – by contrast, many EU countries have thresholds under €50k or none at all. [en.wikipedia.org]
  • 12-month rolling period: The threshold is calculated on a rolling basis, not by calendar year. At the end of each month, a business must look at its cumulative taxable turnover for the past 12 months. If it has exceeded £90,000, the business must notify HMRC within 30 days and register. The registration will take effect from the end of the month following the month it went over (or immediately if the next 30 days criterion applies). For example, if at end of July your past Aug–July turnover = £92k, you must notify by end of August; HMRC will register you effective 1 September.
  • Next 30 days rule: If at any point the business expects to make taxable sales exceeding £90k in the upcoming 30 days alone (perhaps due to a one-off big contract), it must register immediately (this is an anti-avoidance measure to catch sudden large spikes). For instance, if on 1 March you sign a deal to sell £100k of goods by 20 March, you know you’ll breach the threshold in 30 days, so you must register by 30 March, effective 1 March.
  • Taxable turnover definition: It includes standard, reduced, and zero-rated sales. Exempt sales are excluded from this calculation (exempt supplies don’t count toward threshold). Also excluded are any sales made while not established in the UK (for foreign biz rules see below), and sales of capital assets can be excluded if one-off (but generally they are still part of turnover calculation if they’re taxable). HMRC’s Notice 700/1 clarifies what to count.
Voluntary registration: Businesses with turnover below the threshold may voluntarily register for VAT if they wish. Many small businesses do choose voluntary registration, especially if:
  • They sell mostly or exclusively to VAT-registered customers (B2B), who can reclaim the VAT – being registered then allows the small business to reclaim its own input VAT and appear more established.
  • They incur significant input VAT (e.g., start-ups with low sales but high setup costs often register to get refunds).
Voluntary registration is allowed for any entity making (or intending to make) taxable supplies, even if turnover is zero or very low. HMRC sometimes might ask for evidence of intention to trade if pre-revenue. Once registered voluntarily, the business must comply with all VAT rules (charge VAT, file returns, etc.), but it can deregister if taxable turnover falls below the deregistration threshold (£88,000 as of 2024) or business ceases.
Non-Established Businesses (Non-residents):
For businesses not established in the UK (overseas companies) making taxable supplies in the UK, the VAT registration threshold is effectively £0 – meaning there is no threshold exemption. If a foreign business with no UK fixed establishment supplies any goods or services on which UK VAT is due, it must register immediately (or have some arrangement like an agent).
  • No threshold for NETPs: HMRC classifies foreign suppliers as “Non-Established Taxable Persons” (NETPs). A NETP must register as soon as it expects to make any taxable supply in the UK, regardless of value. For example, a U.S. company selling £1,000 worth of software to UK consumers (B2C) must register and charge VAT from the first sale, since it has no UK establishment and the £90k threshold does not apply to it. This rule prevents distortion where foreign businesses could undercut UK businesses by not charging VAT on small amounts. [gov.uk]
    • One exception: If the foreign business’s only UK sales are covered by the reverse charge mechanism (e.g., it only provides B2B services where the UK customer accounts for VAT), then the foreign business may not need to register, because it isn’t “making the supply” for VAT – the UK purchaser does. Similarly, if all its UK sales are zero-rated exports, possibly no registration needed (though often to zero-rate an export, one has to be registered; that nuance usually applies more to UK-established exporters).
    • Online sellers of goods: Post-2021, overseas sellers sending low-value goods to consumers have VAT collected through special rules (marketplace or import schemes) – see Distance Selling section. But technically if those special schemes don’t apply, the overseas seller must register.
Special cases requiring registration:
  • Distance sales into Northern Ireland: Under the NI Protocol, EU businesses selling goods to NI consumers may have to register in the UK (for NI) if they exceed EU distance selling thresholds (though since July 2021, OSS largely replaces this). This is a complex scenario – essentially EU–NI is treated like intra-EU distance selling. The threshold historically was £70k/year for EU to UK distance sales (some EU sources say £70,000 ≈ €80k was the UK’s distance selling threshold). Since 2021, the EU’s OSS scheme means EU sellers can choose to account via OSS in their home country for NI sales, or register in NI. If they use OSS, they need an “XI” VAT number via HMRC’s OSS system. This is a niche outcome of NI’s unique position.
  • Acquisitions in excess of £nil threshold for non-taxable persons: Before Brexit, if a UK entity not VAT-registered acquired >£85k of goods from EU, they had to register (the acquisition threshold). Post-Brexit, intra-EU acquisitions by GB aren’t a concept (they’re imports now). For NI, the threshold for acquisitions from EU is aligned with registration threshold as well.
Registration Process: Businesses register online with HMRC (using the VAT1 form data). Once registered, HMRC issues a VAT certificate and number (see Section 4). Registration can be as a single entity, or if you have divisions or separate trade names, you still get one number (unless you apply for divisional registration). Groups of companies can apply for VAT Group registration (Section 6) where one number covers all.
Timelines and Penalties: Failing to register on time can lead to a penalty and needing to pay VAT for the period you should have been registered. The penalty can be a percentage of the VAT due during the period of failure (ranging from 5% to 15%, depending on how late and whether prompted by HMRC). It’s important to monitor turnover carefully.
Deregistration: If a business’s taxable turnover falls below the deregistration threshold (£88,000) or it ceases trading or no longer makes taxable supplies, it can apply to deregister. Upon deregistration, it may have to account for VAT on any stock or assets on hand if their value is over £threshold (currently £5,000) – effectively a self-supply.
One Stop Shop (OSS) and IOSS (Import OSS) schemes: These are EU schemes introduced in July 2021. The UK is not part of the EU OSS/IOSS for sales to the EU (except NI for goods OSS). Conversely, EU businesses cannot use OSS to report UK VAT (they must register in UK if required). However, the UK has analogous simplifications:
  • For digital services B2C: The UK used to be part of the EU Mini One Stop Shop (MOSS) for telecoms/broadcast/e-services. After Brexit, UK businesses lost access to the EU MOSS for their EU sales – they now register in an EU country for the Non-Union OSS to report EU consumer digital sales. Similarly, non-UK businesses selling digital services to UK consumers must register for UK VAT (the UK did not maintain a Moss-equivalent portal for foreign suppliers; before EU MOSS existed, the UK had a scheme called VAT on e-Services (VOES) for non-EU suppliers – post-Brexit, HMRC effectively reverted to requiring direct registration or using an agent for overseas digital providers). So OSS/IOSS do not spare anyone UK registration except in NI circumstances. [gov.uk]
  • For distance sales of goods to UK: See Section 18 on distance selling – the EU’s IOSS (import one stop shop) is for imports into the EU. The UK instead implemented its own £135 rule and marketplace deeming (no OSS for that, but rules that avoid multiple registrations in EU perhaps).
Summary: A UK business must register for VAT when its taxable turnover > £90,000, or if at any point it expects to exceed that soon. Even below that, it may register voluntarily to reclaim VAT. An overseas business with no UK establishment must register as soon as it starts making taxable supplies in the UK (no threshold). Special relief schemes like OSS/IOSS primarily apply to EU trade; for UK VAT, foreign traders generally need a UK VAT number if they sell to UK customers and VAT is due. [gov.uk]
(Citations: VAT Act 1994 §3-6 covers liability to register; HMRC Notice 700/1 on registration. Wikipedia notes the threshold as of 2024 is £90,000. HMRC policy paper confirmed the rise to £90k from April 2024. HMRC guidance on “Refunds of UK VAT for non-UK businesses” implicitly shows foreign businesses must reclaim via special scheme since they had to pay VAT – meaning they had to register if making supplies. The reciprocity clause in that guidance also highlights foreign businesses needing direct registration in many cases, see Section 16.) [en.wikipedia.org] [gov.uk], [gov.uk]
6. VAT Grouping Rules
The UK allows VAT Group Registration as an administrative simplification for closely related corporate entities. Under VAT grouping provisions, two or more businesses can be treated as a single taxable person for VAT purposes, meaning they have one VAT registration number and file a single consolidated VAT return for the group. Key points about UK VAT grouping:
  • Eligibility – Control and Establishment: VAT grouping is permitted for “bodies corporate” (companies, LLPs, etc.) and certain other entities (individuals or partnerships) that are under common control, provided all members of the group have an establishment in the UK. Historically only corporate bodies could join, but since 2019, HMRC expanded eligibility to non-corporate entities if they control (e.g. owning companies) or are controlled by corporate members. The key criteria are: [gov.uk], [gov.uk] [gov.uk]
    • Establishment: Each entity in the group must be either legally established in the UK or have a fixed establishment in the UK (a branch or place of business). You cannot group a company that has no UK presence at all. [gov.uk]
    • Common Control: There must be 50% or greater common control (usually common ownership by one legal person or holding company) among the entities to be grouped. Typically, a parent company and its subsidiaries (where the parent owns >50% of each) qualify. “Control” is defined by reference to the Companies Act definition of a holding company’s control of subsidiaries (generally more than 50% of shares or voting power). All members must be “closely bound by financial, economic and organizational links.” In practice, HMRC uses control as the test. [gov.uk]
    • Partnerships and sole traders can group with companies if, for example, an individual controls a company and also runs a sole proprietorship – since 2019 the rules allow grouping in such cases (though this is less common in practice).
  • Effect of Grouping:
    • The group is treated as a single taxable person. The group will have a single VAT number (usually that of the representative member). One entity is nominated as the representative member – this entity deals with HMRC, submits the VAT returns, and usually pays/refunds VAT on behalf of the group. All VATable transactions by any group member are considered made by the group as a whole. [gov.uk]
    • Intra-group supplies are disregarded for VAT purposes – meaning no VAT is charged on goods/services exchanged between group members. For example, if Company A and Company B are in a VAT group, and A provides management services to B, A would not charge VAT on those services (the supply is “ignored” for VAT). This can simplify accounting and avoid cashflow issues when one group member charges another. (Important: disregarded supplies also mean no VAT to reclaim on them, since they are ignored altogether; the supplying member doesn’t output VAT, the receiving member doesn’t have input VAT – but that generally doesn’t matter as it nets off within one entity in HMRC’s eyes.) [gov.uk]
    • The group as a whole has joint and several liability for VAT debts. HMRC can recover any VAT due from any member of the group if the representative member doesn’t pay. This is something to consider from a risk perspective when grouping disparate businesses. [gov.uk]
    • Purchases and sales made by any group member are treated as made by the representative member (or by “the group”). For example, if one company imports goods, the import VAT is declared under the group’s VAT number; if another company makes a sale, it issues an invoice with the group’s VAT number and that sale goes on the group VAT return.
  • Benefits of Grouping:
    • Cash flow and admin simplification: Only one VAT return for the whole group, rather than multiple returns for each company – reduces compliance burden. Intra-group billing doesn’t create unnecessary VAT payments/refunds.
    • No VAT on inter-company charges: Useful if you have major inter-company transactions (like a centralized service company charging subsidiaries) which would otherwise cause VAT to circulate. Particularly good if some members don’t have full VAT recovery: But caution, if one member is partly exempt, grouping them with a fully taxable company could actually taint the whole group’s recovery (see below).
    • Single point of contact: dealing with HMRC as one entity can simplify any audits or queries.
    • It can also mask the internal profit allocations – since group returns are aggregate, external parties (or employees of one division) won’t see the internal VAT charges.
  • Drawbacks / considerations:
    • Joint liability – as mentioned, if one member defaults or runs into trouble, the others are on the hook for its VAT. This can be a risk if one member is weak or might incur large liabilities (e.g., a subsidiary involved in aggressive tax positions or likely to incur penalties).
    • Partial Exemption Impact: If one or more group members make exempt supplies (e.g., a finance or insurance arm), it can make the whole VAT group partially exempt, possibly reducing input VAT recovery for the entire group. Because the group is one taxable person, HMRC looks at the combined activities to determine what portion of input VAT is attributable to taxable vs exempt supplies. So, companies that would have been fully taxable on their own might lose some VAT recovery because they are grouped with an exempt business. Groups need to do a single partial exemption calculation each period for the group as a whole. [en.wikipedia.org]
    • Complex structure changes: Adding or removing members requires notifying HMRC (group composition can be changed with approval – adding a new subsidiary, etc.). If companies have very different accounting systems, compiling a single return may add internal admin complexity.
    • Branches vs Separate: Note, VAT grouping is different from having divisions under one VAT number (the latter is called divisional registration, which the UK also allows in special cases – a single company can have separate VAT registrations per division with HMRC approval, but that’s rare; grouping is between distinct legal entities).
    • Overseas entities: Since Brexit, overseas (non-UK) establishments of UK companies cannot join UK groups unless they have a UK fixed establishment. Similarly, UK branches of foreign companies can join if they are within a controlled group with others. A recent change allows HMRC discretion to refuse grouping if it risks VAT evasion/avoidance (Protection of Revenue conditions). [gov.uk]
  • Application and Administration: Businesses must apply to HMRC to form a VAT group (using form VAT50, and VAT51 for adding members). HMRC has discretion to refuse or impose conditions, particularly to prevent tax avoidance (for example, HMRC can refuse grouping if it sees that grouping might allow a largely exempt business to join with a taxable business just to reclaim VAT it otherwise couldn’t – HMRC’s power in Section 43 VATA can deny grouping where it would “result in an overall reduction of VAT payable”). Generally, however, if conditions are met, grouping is allowed. The group chooses a name (often the parent’s name) and a representative member.
    Once approved, the group registration takes effect from a set date. All invoices between members should ideally note “VAT not charged – intra-group supply” or similar, because no VAT applies. Invoices to outside customers bear the single VAT number. If a member leaves the group or the group disbands, HMRC must be informed.
  • Skandia / branch issues: A specific point – in EU law, a 2014 case (Skandia) said an overseas branch can be treated separate for VAT if the head office is in a VAT group in another country, affecting cross-border services and reverse charge. The UK initially did not adopt this interpretation, but post-Brexit it has more leeway. The UK’s position (as of 2026) is that it still broadly does not follow Skandia except where HMRC specifically applied “section 43(2A)” to make certain intra-entity charges taxable if one part is in a VAT group and another is not. This is a niche affecting some financial companies. (HMRC updated policy in early 2024 about disregarding certain internal transactions unless avoidance). For most readers, not critical, but worth noting UK groups can have cross-border branch complications in specific cases. [gov.uk]
Summary: VAT grouping is a useful tool in the UK for corporate groups: it allows treating multiple companies as one for VAT. Supplies between group members are ignored for VAT, and one VAT return covers all. All members must have UK establishments and be under common control. While reducing VAT on inter-company transactions and simplifying compliance, grouping must be considered alongside partial exemption (the group’s mix of taxable vs exempt supplies) and joint liability concerns. [gov.uk]
(References: VATA 1994 Section 43 governs VAT grouping. HMRC VAT Notice 700/2 is the primary guidance. The Notice confirms group members are treated as a single taxable person and mentions joint liability and disregarded supplies. HMRC Internal Manual “VAT Groups” also details eligibility and the new rules (including partnerships). The excerpts provided show the conditions: e.g., “bodies corporate can form a VAT group if each is established in the UK and they are under common control”, and that one member is responsible and supplies between members are normally disregarded.) [gov.uk], [gov.uk] [gov.uk]
7. VAT Recovery for Foreign Businesses (13th Directive Refunds)
(Note: There is some overlap between this section and Section 16 on non-resident refunds. Here, we focus on the concept of how foreign businesses reclaim UK VAT when they are not VAT-registered in the UK. Section 16 will go into EU 8th/13th Directive specifics. We ensure clarity to avoid repetition.)
Foreign businesses that incur UK VAT have two main ways to recover that VAT: either by registering for VAT in the UK (if they themselves make taxable supplies here, as discussed in Section 5) and then reclaiming input VAT on returns, or if they are not required to register, by using the VAT refund scheme for overseas businesses. This overseas refund mechanism is analogous to the EU’s 13th Directive refunds and allows businesses established abroad to get a refund of UK VAT on certain expenses.
Scenario: “Foreign business” in this context means a business that is not established in the UK and does not make UK taxable supplies requiring VAT registration, but does incur UK VAT on local purchases (e.g., attending a UK trade show, buying UK goods to take home, or UK hotel and travel expenses for staff). These businesses cannot reclaim via a regular VAT return (since they aren’t registered), so a special claim process exists.
UK VAT Refund Scheme for Non-UK Businesses:
If a business is established outside the UK and incurs UK VAT on goods or services used for its business purposes, it may be able to claim a refund of that VAT from HMRC under provisions equivalent to the EU’s Thirteenth Directive (for non-EU businesses) or formerly the Eighth Directive (for EU businesses, when the UK was in the EU). After Brexit, EU businesses now also use the “non-Union” procedure with HMRC (so practically all foreign claims fall under one scheme managed by HMRC, since the UK is no longer part of the EU’s electronic refund portal, except NI/EU goods cases).
Conditions for foreign VAT refund (key points):
According to HMRC’s Notice 723A, to be eligible, the foreign business must: [gov.uk], [gov.uk]
  • Not be registered or liable to register for VAT in the UK. Essentially, if you should have registered, you can’t circumvent that by trying a refund claim – you need to register. And if you are voluntarily registered, you would reclaim via returns, not this scheme. So this is for businesses with no UK VAT number and no requirement to have one. [gov.uk]
  • Have no business establishment or usual place of business in the UK. (If they have a UK fixed establishment, they should be registered as a UK business or part of a VAT group, etc., so then not use this scheme.) [gov.uk]
  • Make no supplies in the UK (during the claim period) other than certain zero-rated or reverse-charged supplies. The notice specifies allowed exceptions: the business can still qualify if its only UK supply was one where the customer accounted for the VAT (e.g., B2B services under reverse charge), or transport of goods related to exports, etc. But if it made any standard-rated or reduced-rated supply in the UK, it likely was required to register and thus ineligible for this refund route. [gov.uk]
  • Reciprocity: The UK requires that the country where the business is established offers similar VAT refund arrangements to UK businesses (reciprocal treatment). HMRC will refuse an application if the claimant’s country doesn’t reciprocate. In practice, the EU countries and many others (e.g., Norway, Canada, Japan, etc.) allow VAT refunds to UK traders, so UK allows theirs. Businesses from countries that have no VAT or don’t refund to foreigners might be denied (though if no VAT in home country, often UK still refunds – see below – reciprocity mainly hits countries like the US where sales tax might not be refunded to foreign govts; historically UK still refunded to US businesses despite US not having VAT, as US has no scheme; Notice 723A implies refusal only if that country has a turnover tax refund scheme but bars UK businesses). [gov.uk]
    Reciprocity example: UK lists that it does not refund to businesses from some countries unless those countries allow UK claims. For instance, if a business is from a country with no VAT (e.g., Gulf countries before they introduced VAT), HMRC might still process it. But if from a country like China or Russia that has VAT but doesn’t refund foreigners, HMRC might reject. In practice, EU, Canada, Japan, Norway, Switzerland, etc., are fine; one needs to check HMRC’s lists.
What VAT can be reclaimed by foreign businesses:
The scheme allows reclaim of UK VAT on purchases of goods or services in the UK which are for the purpose of the claimant’s business activities outside the UK. Typical reclaimable expenses include:
  • Travel and accommodation expenses for employees on business trips to the UK (hotel VAT, restaurant meals if not business entertainment, conference fees with VAT, transport within UK if VAT-charged like car rental).
  • Trade fairs or exhibition costs: booth fees if VAT included, printing, marketing services bought in UK for the event.
  • Goods purchased in UK and removed from UK (exported) can often be zero-rated if exported directly, but if not zero-rated then foreign buyer might reclaim (though they should try to get zero-rating if possible).
  • Import VAT that the foreign business paid when importing goods into the UK for say a trade show or temporary use can be reclaimed via this scheme (the notice explicitly says VAT on imports can be refunded). [gov.uk], [gov.uk]
  • Services purchased in UK (professional consulting, UK advertising, etc.) that had VAT. If those services relate to the foreign business’s taxable activities abroad, they can reclaim.
However, certain UK VAT cannot be reclaimed even by foreign businesses, similar to UK domestic rules on blocked input tax:
  • VAT on cars hired or purchased for private/business mixed use is blocked (50% rule or full block on cars as per UK law). [gov.uk]
  • VAT on business entertainment (taking clients out to dinner, etc.) is not reclaimable – UK disallows input VAT on entertaining except in limited cases (entertaining overseas customers can be reclaimed only if it’s “of a very basic nature” – HMRC sets a high bar). So foreign businesses also cannot reclaim UK VAT on entertaining. However, VAT on staff subsistence (meals for your own employees on a trip) is allowable because that is not entertaining, it’s employee expenses. [gov.uk]
  • VAT on goods/services not for business use (non-business) – obviously not.
  • Some specific items: e.g., non-UK EU businesses cannot use this scheme for VAT on goods they acquired in NI/EU context (they use the EU 8th Directive method instead for NI, see sect.16).
  • Goods for resale to travelers: According to Notice 723A, VAT on goods bought in UK for direct resale to travelers (e.g. in airport shops maybe) cannot be reclaimed (to avoid someone using this scheme to effectively run retail without registering). [gov.uk]
  • Anything that a UK business couldn’t reclaim if in same position, the foreign business also can’t. (E.g., VAT on a UK residential building purchase – if even a UK developer couldn’t reclaim because it’s exempt sale – a foreign buyer can’t either.)
Claim process and timeframe:
Foreign businesses must submit a VAT refund claim to HMRC. Key points:
  • Period: The claim can cover a period between 3 months and 1 year (can be shorter if it’s the remainder of a calendar year). Often claims are done for a calendar year (e.g. Jan–Dec 2025 expenses, claim in early 2026). It cannot cover more than 12 months, or less than 3 months unless the period is what’s left of a calendar year (e.g. a company could claim Jan–Mar or Jan–Jun, etc.). In practice, HMRC allows quarterly or annual claims.
  • Deadlines: Claims must be submitted by 31 December of the year following the claim period. So, expenses from 1 Jan to 31 Dec 2025 must be claimed by 31 Dec 2026. If missed, you lose the right. (Earlier if partial year: e.g., a claim for Jan–Jun 2025 also must be by 31 Dec 2026 – basically always 31 Dec of next year). This is aligned with the “13th Directive” timelines, which UK follows. [gov.uk], [gov.uk]
  • Minimum claim amounts: If the claim period is less than a year (but at least 3 months), the minimum claim is £130 (UK set this historically when threshold was £250 pre-2009, it lowered to align with EU’s €400). If the claim is for a full year (or the remainder of a year that’s under 3 months), the minimum is £16 (again matching EU’s €50 historically). These values ensure HMRC isn’t handling trivial claims. So a foreign business must have at least £130 of UK VAT to reclaim in a quarter, or £16 if a whole year. (These amounts are relatively small, easy to exceed with one hotel stay.) [gov.uk]
  • Method: Prior to Brexit, EU businesses applied via their home country’s portal (8th Directive electronic system) – not applicable now. All businesses (EU or non-EU alike) must apply directly to HMRC. The UK has an online service where you fill Form VAT65A (or now an online equivalent; the VAT652 referenced in results is for error corrections, not this – pardon). Actually for foreign refunds, the form is VAT65A plus a Certificate of Status (VAT66 from home tax authority). The claimant must provide: [gov.uk], [gov.uk]
    • A certificate from their home tax authority proving they are a business registered for sales tax/VAT or analogous (valid for 12 months). For EU businesses, HMRC accepted a printout of their VAT registration perhaps, but now likely still require a VAT66 or equivalent. This proves the foreign entity is bona fide and not small consumer. This certificate is usually issued by the tax authority in the claimant’s country – valid for a year. [gov.uk], [gov.uk]
    • Original invoices or import documents showing the VAT (HMRC often expects proof of VAT paid). Increasingly, scanned copies may suffice – HMRC now allows digital submission of evidence. But originally, one had to mail hard copies. [gov.uk]
    • Banking details so HMRC can pay the refund electronically (SWIFT, IBAN details). [gov.uk]
    • Completed claim form listing each invoice’s details: supplier, date, amount net, VAT, category of expense.
  • Processing time: HMRC aims to process such claims within 6 months of receipt (the law actually gives HMRC up to 6 months to make the refund). If approved, HMRC will refund the VAT in GBP, usually via an international bank transfer to the claimant’s bank (or to an agent’s account if authorized). They pay in GBP; the claimant’s bank may convert to local currency. If HMRC rejects or partially disallows items, they will send an explanation, and the claimant can seek a review or appeal within 30 days. [gov.uk] [gov.uk], [gov.uk]
Fiscal representatives: Unlike some countries, the UK generally does not require a foreign claimant to appoint a UK fiscal representative just to use the refund scheme. The claim can be made directly by the foreign business or via an agent (with a simple letter of authority or power of attorney). However, if a non-UK business is actually required to register for VAT (because it’s making supplies), then whether it needs a fiscal rep is another matter (covered in Sec.8). For just refund claims, typically no fiscal rep needed, but an agent can handle paperwork if desired. [gov.uk], [gov.uk]
Recent Brexit changes: When the UK was in the EU, EU businesses claimed UK VAT through the electronic EU VAT refund system by 30 Sept of following year (8th Directive). Post-Brexit, EU businesses now have to use this same “overseas” process but HMRC gave a transitional extension for 2020 claims, etc. Now it’s uniform: all foreign businesses (EU or not) use form VAT65A to claim UK VAT, by 31 Dec deadline. In HMRC’s terms, after 1 Jan 2021, EU businesses fall under “Section 2” of Notice 723A along with everyone else. [gov.uk]
Example: A Canadian manufacturing company sends engineers to the UK to install equipment for a UK client. The Canadian company isn’t registered in the UK (the installation service is B2B, place of supply is UK? Actually installation of goods is UK supply which might have needed registration – but let’s assume it was under reverse charge if UK customer took on accounting via some rule or the Canadian isn’t obliged for some reason). Meanwhile, the Canadians paid VAT on their hotel bills and tool rentals in the UK. They can accumulate those invoices and by the next year file a refund claim to HMRC with supporting invoices and a certificate from CRA that they’re in business. HMRC validates and refunds the VAT to their Canadian bank in a few months.
In summary, foreign businesses not VAT-registered in the UK can often recover the UK VAT incurred on business expenses via a special refund scheme, provided their home country reciprocates and they follow the claim procedures. This ensures VAT is not a cost for businesses doing cross-border trade, aligning with the principle that VAT is a tax on local consumption, not on exporters or foreign investors. [gov.uk], [gov.uk]
(Citations: HMRC Notice 723A (Dec 2020 update) is the primary source. Lines cited confirm conditions: not registered, no place in UK, reciprocity needed. Also it outlines allowed and disallowed items (section 2.3 of notice excerpt covers what can/can’t reclaim). The timeline and process references are drawn from notice and common 13th Dir practice.) [gov.uk], [gov.uk] [gov.uk], [gov.uk]
8. Fiscal Representative Requirements
A fiscal representative is a local agent jointly responsible for VAT compliance and payment. Many countries require non-resident businesses to appoint a fiscal rep to register for VAT, especially if the business is from a country without mutual administrative assistance agreements. The UK’s rules around fiscal representatives have evolved, particularly after Brexit:
General rule in the UK:
The UK does not generally mandate a fiscal representative for foreign businesses registering for VAT, provided the business is established in a country with a reciprocal administrative cooperation arrangement (or considered low risk). Historically, while in the EU, the UK did not require EU businesses to have fiscal reps (due to EU freedom of establishment and mutual assistance), and did not commonly require non-EU businesses to have one either, except in specific anti-evasion cases.
After Brexit, the UK gained the ability to impose fiscal rep requirements on EU businesses, but chose not to broadly apply that in most cases. Instead, HMRC retains discretionary power to direct certain non-established taxable persons (NETPs) to appoint a UK fiscal representative where necessary to secure the revenue. [gov.uk], [gov.uk]
Key points:
  • Discretionary Requirement: Under VATA 1994 Section 48, HMRC can direct a non-UK established person to appoint a VAT representative (with joint liability) if the person is not established in an EU member state. Post-Brexit, this effectively means any business established outside the UK (including now EU businesses) could be subject to such a direction. However, HMRC typically uses this power for high-risk cases (like overseas online retailers who might default on VAT). This power was strengthened in 2016 to combat VAT evasion by some overseas sellers on online marketplaces (this was part of the “joint and several liability for marketplaces” measure – before the marketplace joint liability rules came in 2018, HMRC sometimes required Chinese/American Amazon sellers to have UK fiscal reps or give security). [gov.uk]
  • Current policy (2026): HMRC’s public guidance (Notice 700/1) states “If you do not have a business establishment in the UK, you do not normally need a fiscal or tax representative to register for UK VAT.” Instead, you can register directly. However, HMRC may require one if you’re in a country without a sufficient information exchange arrangement. After Brexit, the UK and EU agreed on continued mutual assistance on tax matters (the Trade and Cooperation Agreement includes VAT cooperation), so HMRC did not impose across-the-board fiscal rep requirements on EU businesses. Similarly, businesses from countries like Norway, Canada, etc., where mutual assistance treaties exist, can register directly.
  • When is a fiscal rep required by HMRC? Typically:
    • If the business is in a country that does not have a VAT mutual assistance agreement or similar treaty with the UK. For example, if a business is based in a jurisdiction known for non-cooperation, HMRC might demand a rep or security.
    • If the specific sector is high-risk for non-payment (e.g., online marketplace sellers from overseas in the past).
    • The law specifically after 2016 allowed HMRC to require a rep for non-EU businesses selling goods online (this was to enforce marketplace compliance). Now that even EU are “non-EU” from UK perspective, HMRC’s stance is: where necessary they can direct the business to appoint a rep who is “fit and proper” and often require that rep to provide a financial guarantee. [gov.uk]
    • Security deposits: As per that update, HMRC can also ask a NETP for a financial guarantee directly (bond) instead of rep, or both. [gov.uk]
  • Nature of fiscal rep: If appointed, the UK fiscal representative must be UK-established and is jointly and severally liable for the VAT debts of the non-resident business. That’s why reps usually ask for a bank guarantee or some security from the client. [gov.uk]
  • Post-Brexit for EU businesses: Initially, there was concern the UK would require EU companies to appoint reps (and vice versa many EU states did impose requirement on UK businesses as of 2021). However, the UK in 2021 passed legislation to waive the fiscal rep requirement for businesses from certain countries, including all EU member states, on the basis of reciprocal tax agreements. Specifically, the Value Added Tax (Accounting Procedures for Overseas Persons) (EU Exit) Regulations 2020 allowed HMRC to continue not requiring reps if mutual assistance is in place. For example, Belgium requires UK businesses to have a fiscal rep because UK is “third country” (though Belgium later waived it for UK in 2021 due to an EU-wide reciprocity list possibly?), but the UK did not reciprocally force Belgian companies to get a rep since there is cooperation via the UK-EU agreement (the excerpt in enterprise content about Belgium confirms Belgium waived requirement for UK due to UK mutual assistance pact).
    In short, for EU, Norway, and other cooperative countries, no UK fiscal rep is needed to register – they can “direct register” as before.
  • Conclusion: In practice, most foreign businesses can register for UK VAT directly, without appointing a fiscal representative. The registration form for non-UK businesses (VAT1) just requires a UK contact address (can be an accountant or business address), but not necessarily a formal fiscal rep. Only if HMRC explicitly issues a notice requiring a rep would one be needed. And those cases are relatively rare and targeted.
Examples/Notable points:
  • Many US, Chinese, EU companies are registered for UK VAT and file returns themselves or via UK accountants, with no fiscal rep. Instead, since 2018, the focus was on making online marketplaces liable if their sellers don’t comply, rather than forcing thousands of sellers to get reps.
  • After Brexit, some EU countries made fiscal rep mandatory for UK firms (France, Spain, etc.), but the UK didn’t fully reciprocate. Instead, HMRC’s stance is more lenient, trusting the new agreements.
  • A scenario where HMRC did use this power: Prior to marketplace joint liability rules, HMRC started sending notices around 2017 to some non-EU sellers that they must appoint a UK VAT rep or provide security. This was targeted and is still available for HMRC to use if needed.
  • Costs: If a fiscal rep is required, the foreign business will have to find a UK-based tax professional willing to act. This can be expensive (they might charge a retainer or require a large security). The representative is often jointly liable, so they often demand a bank guarantee to cover possible VAT debts.
Related concept – Tax Agent vs Rep: A fiscal rep has legal liability. A tax agent or VAT consultant in UK can handle filings for a foreign business, but they are not liable – they act under the business’s authorization but not as a “representative” in the legal sense. Many foreign businesses simply use UK accounting firms as agents (not reps) – which is allowed. Only if HMRC specifically requires a Section 48 VAT Representative does that agent become a joint-liability rep (and both must sign acceptance).
Northern Ireland / EU angle: One nuance: For distance selling into NI by EU companies, if an EU company didn’t want to register under OSS, it could register directly in the UK for NI. It wouldn’t need a rep because EU is covered by mutual assistance. Similarly, EU businesses selling services in UK (which seldom cause registration because most B2B services are reverse charged, B2C intangible services since Brexit might cause need to register) – if they do register, no rep needed. However, for EU claiming 8th Directive refunds in NI: the TCA ensures cooperation, so no rep needed for claims either.
Takeaway: There is no automatic fiscal representative requirement in the UK for overseas businesses. HM


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