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To be clear, because the entity making the sales is Hong Kong based, it is not a UK established company, therefore the VAT registration threshold is Nil, so any sales of any value would trigger UK VAT registration. If it were a UK entity/UK limited company, then the VAT threshold would be £85,000.
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Hi HMRC Admin
This issue has been ongoing for 3 months at least now, it cannot be that difficult for a database to talk to another database.
It used to work before you switched platforms, the issue is preventing legitimate taxpayers from trading, if you can escalate this with your outsourced IT folks as a matter of urgency as taxpayers can't trade via online marketplaces without a valid VAT number. HMRC must be missing out on hundreds of thousands of pounds of revenue due to these delays.....one for the Public Accounts Committee perhaps?
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There is no such thing as a "VAT exemption certificate". Who is advising you on this?
If you mean a zero rating certificate for certain medical equipment, these are supplied by the customer when the conditions for zero rating are met, the main conditions are that the customer is a charitable entity using donated funds to purchase the medical equipment https://www.gov.uk/guidance/charity-funded-equipment-for-medical-and-veterinary-uses-notice-7016#zero-rating-goods-and-services-bought-with-charitable-or-donated-funds
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It's not "VAT exempt", the supplies you describe are outside the scope of VAT. It matters because outside the scope of VAT means you can register for VAT optionally, whereas if your supplies are truly "exempt", then you have no right to register for VAT or reclaim input tax.
The place of supply of services is primarily determined by where the contractual client is, in your post that seems to be Company B....or in other words, who is your client billing?
You should also look at HMRC Notice 741A (Place of supply of services) and look at section 13 https://www.gov.uk/guidance/vat-place-of-supply-of-services-notice-741a#sec13 which covers "use and enjoyment rules", which in brief, if your client is supplying certain electronic services to a USA client but the services your client supplies are enjoyed in the UK (by Company C), then even though the place of supply indicates the customer is USA/outside the scope of VAT, the use and enjoyment rules shifts the liability back to the UK.
Some useful examples within the HMRC internal manuals here https://www.gov.uk/hmrc-internal-manuals/vat-place-of-supply-services/vatposs15000
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The zero rating applies only to the supply AND installation of energy saving materials such as PV/batteries.
The contractor will buy materials from wholesaler, those materials will be plus 20% VAT as it's just materials. The contractor then installs those materials to your property - the act of installing those materials should see the whole supply (materials + labour) being zero rated. the contractor can reclaim the VAT they incur when they buy the materials. If your quote is including VAT at 20% then you should challenge the contractor and ask why they have not zero rated their quote.
Note, the install of PV/batteries is zero rated, not "exempt", in your post you refer to VAT exempt status, there is no exemption from VAT, VAT is charged but at 0% so when speaking with contractor use the correct language so that there is no ambiguity with them.
If you buy materials yourself from a wholesaler, they will be plus 20% VAT.
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HMRC always verify the first VAT return of any newly VAT registered business.
It has often been the situation that HMRC can take up to 30 days before making contact with the taxpayer, although HMRC usually make contact within 14 days but can take a little longer, especially around the summer holiday season.
Your only realistic option is to just wait for the email or call from HMRC. In the meantime, HMRC will want to see copies of 5 or 6 of your highest VAT valued purchases, and also the same for sales. HMRC often ask for bank statements covering the VAT return period, so if you get all of these ready and waiting, when HMRC ask for these, you can reply straight away.
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Follow this link https://www.gov.uk/vat-repayments
Scroll down page to :-
For HMRC to make a payment into your overseas bank account, it must be:
in the name of the company owed a repayment
associated with a named business owner or an authorised person with a Government Gateway ID
able to accept repayments in pounds sterling
You must "fill in a form to give details of your overseas bank account before HMRC can transfer any VAT repayments". All VAT repayments will then be sent to this bank account.
Click the link "fill in a form to give details of your overseas bank account before..." You will go to your gateway login page, log in and you will be asked a series of questions about the business (address, VAT registration date, VAT number, etc) and then HMRC will process your request in 2-3 days.
You cannot access this bank page by going to your normal gateway login, you have to visit the https://www.gov.uk/vat-repayments first and then click the link on this webpage to get to your gateway.
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The issue might be that the vehicle was purchased second hand.
A new car adapted for disability use would be zero rated by the dealership.
When the same car is traded in by the owner, the dealership acquires that vehicle without VAT (not zero rated, zero rate is a rate of VAT, I mean the vehicle is acquired without any VAT whatsoever as the seller is a consumer/individual who is not VAT registered, the seller cannot sell a car at zero or standard rate of VAT as they are not VAT registered.
If the car was purchased under the 2nd hand margin scheme, the invoice will state "margin scheme applies" somewhere on the invoice, if that is the case, then technically the vehicle you bought was not zero rated, it was sold to you with VAT being charged on the sale but without the VAT showing on the invoice.
Margin scheme works like this. Dealer buys trade in car from customer for £10k and manages to sell it for £11k. The profit margin is £1k and the dealer declares output tax on that £1k (£1k x 1 /6 = £166 VAT) but dealer not allowed in law to show the VAT, the sales invoice will just show £11k and wording that says "sold under margin scheme" or something to that effect.
Have a look at the Notice again https://www.gov.uk/guidance/vat-relief-on-adapted-motor-vehicles-for-disabled-people-and-charities-notice-1002#sec8 but check out section 9 which talks about 2nd hand cars
What it says is when you bought the 2nd hand car, the dealer could have just zero rated the sale to you (and thus qualify as an adapted vehicle) or they could have used the margin scheme whereupon they probably charged VAT albeit on the margin and not shown on the invoice.
If the invoice clearly shows zero rated VAT then no issue, but if it makes reference to margin schemes or shows no VAT at all, then that may be why the garage are being a bit prickly about things. garage is perhaps being a bit unhelpful but clearly not prepared to take any risk whatsoever.
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https://www.gov.uk/hmrc-internal-manuals/vat-trader-records/vatrec12000
VATREC12030 - Rounding on invoices and rounding at retailers: What do we mean by rounding up and down?
The rules for this are simple:
If the VAT on any transaction comes to less than 0.5 of one penny, it should be rounded down.
If the VAT comes to 0.5 of one penny or more, it should be rounded up.
This is the same system as that outlined in EU Council Regulation 1103/97, which sets out the rules for converting national currency values into Euro.
However, if a trader proposes an alternative rounding method then it should be considered and allowed if it produces a fair and reasonable result.
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Rosina
It depends on what it is you are selling to the USA customer. You've not stated what it is you have supplied.
It is probably an outside the scope of VAT supply, but I'd use T0 (zero rate) that way Sage will allow you to produce an invoice and also populate the VAT return correctly (Box 6 sales excl. VAT) and Nil in Box 1 (output tax due on sales).
If you are supplying land or where performed services, then the VAT could be standard rated and your invoice is correct.