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Posted Thu, 27 Jun 2024 17:27:00 GMT by Oak Row
We sell goods as a UK company to overseas customers and categorise these sales as zero rated. At times our goods transit straight from the European factory or European warehouse to the overseas customer and we categorise these sales as outside the scope of UK VAT. Is this correct? How do we categorise VAT on carriage when an invoice includes goods from both origins?
Posted Mon, 01 Jul 2024 05:50:17 GMT by Jay Cooke
Place of supply of goods - https://www.gov.uk/hmrc-internal-manuals/vat-place-of-supply-goods/vatposg3300 - is where the goods are at time of sale/dispatch. Where the goods are physically in the UK and they are shipped/exported to outside the UK, this is a zero rated sale, as you have already stated is the case in your post above. Where the goods are physically outside the UK and EU (for example a Chinese supplier drop-shipping direct to your customer), then these sales are outside the scope of VAT. So where the goods are physically stored not in the UK, then you are correct that those sales (sales where the goods are not in the UK), are outside the scope of UK VAT. But having accepted that the place of supply of goods is where the goods are at time of sale, where you are shipping goods directly from an EU supplier, then technically what is happening is that you (UK entity) acquire the goods from the EU supplier in the EU, you then own these goods in the EU and you ask the EU supplier to ship your goods to your customer. The EU supplier is not shipping those goods with their own invoice inside the parcel are they? If they did, the customer might ask why they are buying from you (with a mark-up) when they could buy direct from the EU supplier. If then, you accept that you take ownership/acquire goods in the EU member state where the supplier is based, then it would mean you are obliged to register for VAT in that EU member state (you are a non-EU business making supplies of goods from an EU location). It is surprising that the EU supplier is not charging you EU VAT (although you don't actually state whether the supplier is charging EU VAT or not), but if they are not, then that is their issue but be mindful that in the future the supplier may get a tax inspection from their local tax office and may be required to backdate VAT charges to you. If they are charging you EU VAT, then you cannot reclaim this on the UK VAT return and it simply becomes a base cost which eats into your margin. If you were VAT registered in the EU member state where the goods dispatch from, you would zero rate the sale and declare as such on your EU VAT return.
Posted Tue, 02 Jul 2024 08:51:51 GMT by HMRC Admin 21 Response
Hi Oak Row,
If you export goods from the UK overseas then these would be categorised as zero rated exports if the conditions are met below:
3. Conditions and time limits for zero rating
If the goods are sold within the EU and move between 2 third countries then this will be categorised as Outside The Scope as the goods do not enter the UK.
Please see the Place of Supply Rules for the movement of freight both from the UK and from third countries:
3. Place of supply.
Thank you.

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