Jason Croke

Correct terminology is that the books are zero rated (not exempt). As a non-established person (you are not a UK person) then the £85,000 threshold does not apply to you, that £85,000 only applies to UK established traders. For non-UK traders, the threshold is Nil. Books are indeed zero rated and it is possible to request "exemption from registration", that is, you are required to register for UK VAT (because you are non-UK and selling VATable books and the registration threshold for you is Nil), but you ask for exemption on the basis the things you sell are zero rated and there would be no VAT due to HMRC. When you try to register for UK VAT via the government gateway/website, there should be a question near the start of the questions for exemption from registration, tick that box/click that button and there are less questions asked and HMRC should then write to you to confirm your exemption has been accepted. Whether Amazon will accept that is a separate matter. Amazon platform applies strict rules on merchants, so Amazon may only allow you to sell if you have a UK VAT number, even if you don't technically need one, so it may be best to try the exception route to get the HMRC letter as Amazon aren't always the most flexible in their approach. See paragraph 2.4 of the below link https://www.gov.uk/government/publications/vat-notice-7001-should-i-be-registered-for-vat/vat-notice-7001-should-i-be-registered-for-vat https://www.gov.uk/government/publications/vat-notice-7001-should-i-be-registered-for-vat/vat-notice-7001-should-i-be-registered-for-vat

Once your sales invoice is 6 months past due date, then you reclaim the output tax in Box 4 of the VAT return. Section 2.4 https://www.gov.uk/guidance/relief-from-vat-on-bad-debts-notice-70018 The 6 months is not from the invoice date but from the date invoice is due. For example, if the invoice is issued 01 January and with "payment within 28 days", then the customer has until the 28th January to pay the invoice, so you count the 6 months from the 28th January. If your invoices are "payment immediate", then you can use the invoice date. On a technical point, you have still made a supply for VAT purposes, you still dispatched goods to the customer or supplied a service to the customer, so for VAT purposes, a tax point has been created, but where the customer hasn't paid you, then bad debt relief allows you to claim back the output tax you originally charged to the customer and paid over to HMRC.

Aberdeen office is where all Non-UK Established Persons (NETPU) are registered from/address used. So any correspondence from HMRC would first go to Aberdeen and it is forwarded onto the overseas trader. You are non-UK established because I presume you have no office, branch or staff in the UK. What should have happened is you register for VAT, your VAT number is confirmed, hardcopy paperwork is sent to your overseas business address. Did you ever receive any paperwork? If you have received letters about overdue payments, then this suggests you have not filed or paid any VAT returns since you were VAT registered or that you've not filed/paid at least one VAT return. Contacting the VAT Helpline is the only way to deal with this. Even if you used a tax agent, we would still have to call HMRC and wait. Why did you register for UK VAT? Are you selling goods in the UK and are you selling them to businesses (B2B) or consumers (B2C)? https://www.gov.uk/government/publications/vat-notice-7001-should-i-be-registered-for-vat/vat-notice-7001-should-i-be-registered-for-vat#non-established-taxable-persons-netps-basic-information.

[Post amended - Admin]

How does the customer (condition 2) "receive, use or benefit " from paying for a property to be cleaned AFTER they've left the property? Surely, the next customer benefits, not the current customer? When I pay a clean fee at a holiday let, I don't feel like I'm getting the "benefit" of the clean, I'm just covering the landlords cleaning fees and the landlord choses to get a third party to clean it for them. The property has to be cleaned whether the landlord or the customer pays. I as a customer cannot choose my own supplier to perform the clean, the landlord elects the supplier, determines the price, customer cannot negotiate anything and cannot hire the property unless they agree to the chosen cleaning supplier and set cleaning fee. You could always get some paid VAT advice from your Accountant who'd give you valuable advice and certainty. The HMRC forum is not able to give specific advice, HMRC would need to see and understand your detailed T&C's, how the property is held out for advertising, what contractual arrangement you have with the cleaners (ie, who does the cleaner invoice for their work) and various other aspects in order to get the VAT advice right. This is why HMRC aren't giving you a definitive answer, too many variables. You could write to HMRC and seek a formal non-statutory written enquiry whereby HMRC, presented with all the facts, can give a formal opinion on the proposed arrangement. https://www.gov.uk/hmrc-internal-manuals/vat-taxable-person/vtaxper38500 https://www.gov.uk/hmrc-internal-manuals/vat-taxable-person/vtaxper37950

As HMRC have stated, you have to look at this from a legal/who owns what view. If Italy are charging you Italian VAT, then the supplier is selling the goods to you in Italy, at the time the goods leave the Italian warehouse, you already own the goods, that container of goods in Italy are yours, if this were a shop, it'd be like sending a guy over to the factory and paying cash there and then, those goods are now yours, in Italy. As the goods haven't left Italy - at the time you paid for them - then it is a domestic (Italian) supply, hence why Italian VAT has been charged. So you incur Italian VAT. Technically, you should also register for Italian VAT (as you now own goods physically in Italy and are shipping them to Ireland, so you are making a taxable supply in Italy)....that may not be as bad as it sounds, you'd be able to reclaim the Italian VAT, you'd then make a zero rated export from Italy to Ireland and as you would have an Italian VAT number, you are making a sale from Italy direct to Ireland which means the transactions falls under the "old/pre-Brexit" intra-EU movement of goods, zero rated on your Italian return, Irish customer accounts for VAT under reverse charge, you do an Italian EC Sales List and Irish customer has no import duty to worry about as it is an EU to EU sale. VAT registration in Italy will cost you approx €2,000 but will pay for itself instantly as you are already on the hook for €15,400 of Italian VAT you cannot get back unless you register in Italy. If the Italians ship directly to you in UK, they would zero rate as an export and you take possession/ownership in the UK (rather than taking possession in Italy), you'd pay UK import VAT (recoverable) and then you make an onward shipment from UK to Ireland, which would be zero rated export on your UK return and Irish customer then incurs Irish import VAT their end, so the Irish customer may incur import duty (as the goods are no longer deemed to be EU and duty free if they've passed through the UK potentially) and the Irish customer will have to pay Irish import VAT their end which presumably they can reclaim but might annoy them in terms of cashflow.. For the sums involved, you need to get proper advice, HMRC forum is not a substitute for advice which is bespoke to your situation and there is a lot of money at stake here.