UK VAT registration for non-resident overseas sellers (HMRC, at any turnover)

A business with no UK establishment registers for UK VAT with HMRC whatever its turnover. The £90,000 threshold is for UK-established businesses, and a non-established business has not been able to use it since 1 December 2012 (VAT Notice 700/1: supplement). You tell HMRC within 30 days of your first taxable sale in the UK, or of the day you expect to make one in the next 30 days (VATA 1994, Sch. 1A). Whether your sales are UK sales depends on where the goods are and what they cost, as the table below shows. This page is only what the UK adds to EU VAT registration. The other UK rules are on the United Kingdom page.

You register at any turnover because the threshold is for UK businesses

The Act has two registration schedules. Schedule 1 applies to a UK-established person and sets the £90,000 test. Schedule 1A applies to a person with no business establishment or other fixed establishment in the UK: it is liable as soon as it makes taxable supplies in the course of a business, or has reasonable grounds to believe it will in the next 30 days (Sch. 1, para. 1, Sch. 1A, para. 1). HMRC states the same for services, digital services included (VAT Notice 700/1).

You have a UK establishment if the place where essential management decisions are made and the central administration is carried out is in the UK, or if you have a permanent physical presence there with the human and technical resources to make or receive taxable supplies. HMRC says that being incorporated in the UK, having a registered, serviced or virtual office, or having an address in the business name is “unlikely to be sufficient by themselves” (HMRC). Its notice adds that it would normally treat a company incorporated in the UK as established there if the company can also make or receive business supplies at its registered business address, and that a registered, serviced or virtual office alone is not enough (VAT Notice 700/1, para. 9.2). Neither test names a third-party fulfilment centre. HMRC’s notice says only that your principal place of business address should not be a UK fulfilment centre.

Where your goods are when sold decides whether you register

The £135 limit counts the whole consignment, not each item. The value is the price the goods were sold for, without transport or insurance (unless they are in the price and not shown separately on the invoice) and without other identifiable taxes and charges. Consignments with excise goods, and gifts, follow other rules. If you change the consignment so that it goes above £135, import VAT and Customs Duty can apply, and you may have to adjust the VAT already accounted for (HMRC, HMRC on Northern Ireland and gifts).

If you sell only through a marketplace to consumers, you can apply for an exemption from registration. With the exemption, you must still register if the marketplace gives you a business customer’s VAT details, if you sell goods located in Northern Ireland to a customer in Northern Ireland, if your goods are in an EU country and your sales to Northern Ireland customers pass the Northern Ireland distance selling threshold, or if you make any taxable UK sale outside a marketplace. That threshold is £8,818 a year, in force since 1 July 2021 and replacing £70,000 (VAT Notice 700/1: supplement, para. 3.1). The notice itself still prints £70,000 in this list. HMRC says not to apply for the exemption if you want to recover import VAT on goods you import and sell through a marketplace (VAT Notice 700/1, para. 12.2). The seller stays liable for import VAT and Customs Duty when it first brings the goods in, and can register to reclaim the import VAT (HMRC).

The EU’s OSS and IOSS do not reach Great Britain. For goods sold to customers in Great Britain, you or the marketplace charge UK VAT at the point of sale and you register with HMRC.

Northern Ireland has its own line for goods of £135 or less

A consignment from outside the UK and the EU, sold direct to a customer in Northern Ireland, carries import VAT instead. The seller accounts for that VAT on its UK VAT return instead of at the border (HMRC). Or you can register for the VAT Import One Stop Shop (IOSS) for consignments of £135 or less sold to consumers in the EU, Northern Ireland or both. A business in Great Britain, or in any country outside the EU and Northern Ireland, must use an intermediary to register (HMRC). For goods located in Northern Ireland when sold to a customer there through a marketplace, the marketplace is liable if the seller is established outside both the UK and the EU, and the seller is liable if it is established in the UK or the EU (HMRC).

How you register, in order

1. Apply online. HMRC tells a non-established person to use its online VAT registration service. You sign in, or create sign-in details the first time. You give an estimate of your taxable turnover for the 12 months from your registration date (VAT Notice 700/1, para. 4.1, GOV.UK).
2. Give an address outside the UK as your principal place of business. It is the place where orders are received and the business is run day to day. It should not be a mail-forwarding, registered-office or third-party address, or a UK fulfilment centre (VAT Notice 700/1, paras. 9.4 and 12.1). Official correspondence goes there (HMRC).
3. Use an agent if you want one. You may have one agent at a time. The agent registers for an agent services account, and HMRC needs your authority by digital handshake or letter. Do not give the agent access to your own online account (HMRC). An agent is not liable for your VAT debts (VAT Notice 700/1, para. 10.6).
4. Wait for the number. HMRC posts a 9-digit VAT registration number with your registration date. If you have heard nothing after 40 working days, HMRC asks you to contact its VAT Registration Service; earlier contact can delay the application (VAT Notice 700/1, para. 4.5).
5. Keep the date in mind. HMRC registers you from the day you became liable, not from the day you applied or were told (Sch. 1A, para. 5, VAT Notice 700/1, para. 4.6). You account for VAT from then, even if you did not charge it. Do not show VAT as a separate item on an invoice until you have the number; send the VAT invoices within 30 days of getting it (para. 5.1).
6. Claim the VAT you paid before registering. The normal rules allow VAT on goods bought up to 4 years before the registration date that are not used up or sold, and on services bought up to 6 months before it (para. 5.2).

A UK VAT representative is optional, but HMRC can ask for a security

HMRC can direct a business with no UK establishment to appoint a UK-established VAT representative only where it appears to HMRC that the business is established in a country with no VAT mutual-assistance arrangement with the UK. The arrangement meant is one with effect by an Order in Council that covers both the exchange of information and the recovery of debts (VATA 1994, s. 48(1)(ba), (1A), Finance Act 2006, s. 173(2)). Neither the Act nor HMRC’s notice lists the countries that have one. Where HMRC has not directed you, you may appoint a representative with its agreement (s. 48(2)).

A representative keeps your VAT records and accounts, accounts for UK VAT for you and is jointly and severally liable for your VAT debts. Any VAT representative, directed or voluntary, must be a UK-established person (VATA 1994, s. 48(1ZA), (2)). One that HMRC directs you to appoint must also be fit and proper in HMRC’s view (VAT Notice 700/1, paras. 10.3 and 10.4). HMRC’s notice says it cannot direct a business based in a country where certain mutual assistance arrangements exist (para. 10.3). HMRC’s notice adds that, in some circumstances, it may still insist on a representative where it thinks that necessary (para. 10.6). The Act’s direction power is the one tied to the home-country test.

A security is a separate power. HMRC may require a business with no UK establishment to provide a security for any VAT that is or may become due, and section 48(7) does not tie that to the home country (VATA 1994, s. 48(7)). What a representative is in the EU is on fiscal representative.

You file a return every period and pay in sterling

A VAT Return usually covers 3 months. The return and the payment are due one calendar month and 7 days after the period ends, and a return is due even when you have no VAT to pay or reclaim (GOV.UK). If you expect to reclaim more than you owe, you can ask HMRC for monthly returns (VAT Notice 700/1, para. 5.6). Returns go in through software that works with Making Tax Digital, and HMRC signs you up unless you are exempt (GOV.UK, VAT Notice 700/1, para. 5.5).

From an overseas bank account you can pay by CHAPS, in sterling, with your 9-digit VAT number as the payment reference (GOV.UK). Keep full records, VAT invoices included, for 6 years from the date the goods are sold (HMRC). The customs number, the EORI number, is separate and is on GB EORI.

A marketplace can ask for your VAT number and remove you

If you do not meet your UK VAT duties, HMRC can tell the online marketplaces you sell through. A marketplace can also remove you if it knows you must be registered and are not, or if you have not given it a valid VAT registration number (VAT Notice 700/1, para. 12.3). A marketplace is liable for VAT on goods located in the UK that an overseas business sells through it, so it checks where you are established. HMRC lists the checks it may make, such as a UK principal place of business, UK directors, a UK bank account or a UK IP address (HMRC). Which sales the EU marketplaces declare is on EU VAT for online sellers.

What happens if you do nothing

A customs duty change for goods of £135 or less is coming

On 13 July 2026 HMRC published a policy paper that would remove the £135 relief from customs duty. It is not in force today, and it does not change the point-of-sale VAT rule on this page (HMRC). The customs side is on EU de minimis.