HMRC has published guidance on a number of VAT changes which will impact businesses which trade with the EU in the event of a “No Deal” Brexit. If you currently sell digital services to consumers in other EU countries, claim VAT incurred elsewhere in the EU or use the EU “VIES” database to check EU customer and supplier VAT numbers, you need to be aware of these changes.

There are a number of parts of the UK VAT system which are derived directly from EU rules and practice. Should Brexit happen on “No Deal” terms then, from 29th March, these will disappear with immediate effect – if you’re affected, you need to know what will replace them. In a Briefing Note issued on 4 February, HMRC highlighted a number of these as follows:

Changes to VAT IT systems

If the UK leaves the EU without a deal you will no longer be able to use certain EU VAT IT systems. If you currently use any of these systems, you should be aware of the following:

• EU VAT Refund Electronic System

To make EU VAT refund claims for 2018 using the EU VAT Refund Electronic System, you should submit these before 29 March 2019, instead of the normal deadline of 30 September 2019. After we leave the EU, UK businesses will be able to reclaim VAT from EU countries, by using the existing processes for non-EU businesses.

• EU's VAT number validation service (VEIS)

If you use VIES to check a customer or supplier’s VAT number, UK VAT numbers will no longer be part of this service after 29 March. A UK-only online VAT number checker will be available on GOV.UK from 29 March. You will still be able to use VIES to check the validity of EU VAT numbers.

• UK VAT Mini One Stop Shop (MOSS)

If you currently use MOSS to declare and pay VAT on sales of digital services to EU consumers, you should submit your return for supplies made between 1 January 2019 and 29 March 2019 via the UK portal by the normal deadline of 20 April 2019. If you want to continue to use MOSS for sales you make after the UK leaves the EU, you will need to register for MOSS in an EU Member State. You should do this by 10 April 2019.”

Get in touch

These changes may not be straightforward to deal with for affected businesses, particularly for those currently within the MOSS regime who will need to consider the best way to deal with sales to EU customers after Brexit. Johnston Carmichael’s VAT team can help you understand the impact of the changes and what you need to do in order to minimise the impact on your business. Please get in touch with me, Nigel Roberts at to find out more at: nigel.roberts@jcca.co.uk.