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Posted Fri, 19 Jul 2024 09:49:16 GMT by Martin
Hi everyone, One of our UK customers has a branch is Southern Ireland (Dublin) and we (the UK entity) are looking to purchase goods from our parent factory entity, based in France, and ship direct to our customers branch in Dublin. We don't want to physically bring the goods into the UK - it doesn't make sense commercially in terms of freight costs, or for the goods to be subject to import duty upon entry into the UK, only to then be shipped on to Ireland. Therefore we want to ship the goods direct from France to Ireland, with invoicing from France to UK to Ireland. If we took this approach, would we need to charge VAT to the customer in Ireland (Dublin)? And would there be any other compliance implications?....i'm just conscious that the goods would be remaining in the EU at all times, and that we're looking to arrange the billing from EU country to UK country to EU country. Thanks, 

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Posted Mon, 22 Jul 2024 14:56:43 GMT by Jay Cooke
The goods might be remaining in the EU at all time (French supplier sends goods to Irish customer), but the ownership of those goods is not all within the EU, presumably when you place order with French supplier, they will bill you for the goods, if so, then you (UK business) takes possession of those goods in France. You take possession of the goods in France, then when the goods ship to Ireland, yes the French supplier arranges the shipping but they are now shipping your goods, not theirs, they've already made the sale to you. I would expect the French supplier to charge you French VAT as the goods - at time of sale - do not leave France (ie, French supplier sells goods to UK business and then French supplier ships those goods as a favour for the UK business, and ships them to the Irish end customer. Since Brexit, UK no longer in the EU and so we can no longer avail of the EU simplification that was called "triangulation", do read the link below because it re-iterates what I've posted here, triangulation is only applicable where it involves a Northern Irish business, which is why HMRC still have the guidance up on their website HMRC "triangulation" link (but no longer applicable guidance for a GB based business) https://www.gov.uk/hmrc-internal-manuals/vat-single-market/vatsm5205  Chances are the UK entity may need to register for VAT in France or Ireland. If this is a one off then it all depends on whether the French supplier charges you VAT (they should but if they too are confused then they may not). If this is going to be a regular thing, then get advice from your Accountant.

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Posted Tue, 23 Jul 2024 10:51:05 GMT by HMRC Admin 21 Response
Hi Martin,
As the goods do not enter the UK at any point then the transactions would be Outside The Scope of UK VAT.
There are two transactions taking place whereby you are purchasing goods from France and selling goods to Southern Ireland.
The Place Of Supply of the purchase and supply of the goods will depend where the goods are at the point of purchase and sale.
There may be a requirement to register for VAT in the member state where your sale takes place and so you would need to contact the authority in that member state.
Thank you.

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