UK Northern Ireland B2C distance selling after Brexit

The UK left the EU VAT regime from 1 January 2021. However, Northern Ireland (NI) VAT and customs has taken up a new dual UK-EU position as part of the Brexit Withdrawal Agreement.

EU to NI B2C VAT rules

EU sellers of goods to NI consumers are still be able to use the Distance Selling rules – meaning they can initially sell to NI consumers under their home EU VAT number and rate. Once they pass the old UK distance selling threshold (ended on Brexit) of £70,000, they need a UK VAT registration. Via this, they charge NI consumers the UK VAT rate and report quarterly to the UK’s HMRC. EU sellers may chose to register voluntarily before reaching this threshold.

Note this threshold rule will change 1 July 2021 when the EU VAT ecommerce package is implemented.

NI to EU B2C VAT rules

NI located businesses (based on their postcodes) may also sell under their UK VAT numbers to EU member states until they pass their distance selling thresholds. Most EU countries set their thresholds at €35,000 per annum. Germany, the Netherlands and Luxembourg have opted for €100,000 per annum.

Non-EU to NI B2C VAT rules

There are new 2021 UK ecommerce VAT rules for sellers or facilitating marketplaces selling to NI and across the rest of the UK (‘GB’). Supply VAT (sales VAT) must be charged by the non-EU overseas seller where the consignment does not exceed £135. Above this threshold and UK import VAT is payable at the UK border.