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Posted Sun, 13 Oct 2024 16:46:02 GMT by peegeearr
Here's my situation: * I run a private limited company registered in Sweden. * I mostly sell consulting services to businesses in Sweden, EU, sometimes the UK; the UK sales are B2B, and therefore invoiced as reverse-charge with regard to UK VAT. * Recently, however, I have started an online newsletter for which I charge small subscription fees; the payments are processed by Stripe. * I have sold one---yes, one---subscription to a UK non-business customer so far. Stripe informed me that I would therefore need to register for UK VAT as an NETP. This struck me as utterly insane, but they were of course correct, and so I have done so. I am now trying to explain the situation to my Swedish accountant, but he is finding it rather hard to credit, and the guidance document doesn't do a very good job of distinguishing between the requirements for UK-established businesses and NETPs. I would therefore appreciate confirmation or clarification of the following aspects of the VAT return for an EU-based NETP, operating as described above: * Box 1 should total only the VAT due on the digital subscriptions; it should *not* include the reverse-charge-eligible B2B consulting sales. * Box 3 will effectively repeat the value from Box 1, as I have nothing to do with shipping things through Northern Ireland. * Box 4 should total only the VAT on any goods or services my firm has acquired from the UK; given the exciting challenges and ludicrous expense of buying things from the UK while based in the EU, this box will contain a zero. * Given box 4 will contain a zero, box 5 will repeat the number from box 1. * Box 6 is where it starts to get confusing: "total value of sales and all other outputs excluding any VAT". Does this refer to *any* my firm's sales, to *any* country, or *only* sales to the UK? With reference to the notes on reverse charge accounting, I have taken it to mean *only* sales to the UK, but that this total should also include reverse-charge invoices for the above-mentioned B2B consulting work, as well as the B2C subscription. Clarification on this point would be greatly appreciated. * Box 7, confusing in the same way as box 7: "total value of purchases and all other inputs excluding any VAT". Does this mean "everything my business has paid out for during the assessment period, except salary", or "only things my business has bought from the UK"? * Box 8: "total value of all supplies of goods and related costs, excluding any VAT, to EU member states." This seems fairly clear, but I'm not entirely sure how it's relevant, given all my VAT dealings with EU are handled through my firm's relationship with the Swedish tax authorities? * Box 9: see box 8 above, I don't see how this is relevant to my VAT liability in the UK. (My assumption here is that boxes 6 thru 9 serve as a sort of overview of the turnover of the business as a whole.) The final point to make is twofold. Firstly, because of the vast imbalance between the amounts I'm taking for B2C supplies of website subscriptions to people in the UK (which is a two-figure sum, and seems unlikely to be much more than a two-figure sum for the foreseeable future), and the amounts I'm invoicing for B2C consulting work to UK clients, the difference in magnitude between box 5 and boxes 6 thru 9 is going to look pretty weird. Secondly, weird differences in magnitude are, as I understand it, the sort of thing that makes people (or, more likely these days, algorithms) decide that some sort of audit may be necessary. Which leads me to conclude that, by playing by the rules and registering for VAT to cover these pocket-change B2C supplies, I have not only ended up costing my business more in lost time and accounting fees than the subscriptions are ever likely to come close to compensating, but have also hugely increased my chances of it being audited by HMRC. (I further conclude that, if everything I've written here is basically correct, the smartest and most profitable thing I could do would be to never sell another subscription to a UK reader again, and thus get myself into a place where I can deregister for UK VAT and never have to deal with this bureaucratic clusterf*ck ever again.) Apologies for the length of this query, but I wanted to be as precise as possible. Your advice would be greatly appreciated.
Posted Mon, 21 Oct 2024 06:05:47 GMT by Jay Cooke
Your analysis of the UK VAT return are correct. Boxes 1 to 5 are exactly as you state. Box 6 should only contain the value of sales made to UK B2C (consumers), the sales you make from Sweden to UK businesses (B2B) are reverse charge and those are declared on your Sweden VAT return only, not the UK return.....remembering that we only need to record UK B2C sales on the UK VAT return as the place of supply of digital services B2C is where the consumer is, but for B2B sales, the place of supply is where the business is but that the business accounts for VAT under reverse charge. Box 6 should not include your domestic Sweden sales or sales to other EU member states/rest of the world., all of those sales are detailed on your Swedish VAT return, Box 7 only concerns itself with purchases made in the UK, as you are not buying anything in the UK, then Box 7 should be Nil, same as Box 4. With regard reverse charge on purchases, I can't think where a Sweden based "digital newsletter"business would be buying in a a service subject to reverse charge....for example if you have a contract with Google or PayPal, these are services based in Ireland and their contract would be with you in Sweden, reverse charge applies but would be reverse charge on your Sweden VAT return. Boxes 8 and 9 are only ever used if you are buying or selling physical goods from/to Northern Ireland, which is highly unlikely if you are only selling digital services. Your conclusion of deregistering for VAT makes sense but is a business decision for you to make, for just one (or possibly two) sales per year then it may be much easier to block customers from UK buying, I have client in both UK and EU who block certain Countries in order to avoid the headaches of registering for VAT in another Country, although the EU does operate MOSS/One Stop Shop which does at least make it easier for a digital business to charge VAT to other EU member states without having to register for VAT in each memberstate.
Posted Mon, 21 Oct 2024 09:28:26 GMT by HMRC Admin 19 Response
Hi.
As you are making supplies to consumers in the UK of a digital nature then there is a requirement to register for VAT and unfortunately there is no VAT registration threshold to adhere to as a NETP.
As regards completing your UK VAT return, box 1 will only show the VAT charged to UK consumers for your digital sales.
Box 2 will be zero and box 4 will show any VAT you may incur in the UK which you can deduct as input tax subject to the following conditions:
Introduction to input tax
Box 6 will will show your total net sales so this will be made up of all sales made, both to private and business customers.
Box 7 will show any net purchases incurred in the UK and boxes 8 and 9 will be zero.
You can see guidance regarding the completion of your VAT return here:
How to fill in each box on your return
HMRC understands that businesses operate in many differnt ways and that there will not always be an obvious relationship between certain boxes on your VAT return, especuially boxes 1 and 6.
Thank you.
Posted Tue, 22 Oct 2024 08:14:07 GMT by peegeearr
Thanks, both. One point of clarification, if I may, as there appears to be a contradiction (or at least an ambiguity) between the two replies? It seems clear that Box 6 should only account for sales to the UK -- but should it include B2B sales invoiced under reverse charges (i.e. *all* sales to the UK), or only those sales where VAT is actually charged as part of the invoice (i.e. in this case the B2C newsletter subscriptions only)?
Posted Mon, 28 Oct 2024 15:47:24 GMT by HMRC Admin 19 Response
Hi,
Box 6 should include all the sales made,including sales which will be subject to reverse charge by the UK customer.
Thank you.

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