Brexit: Advance UK VAT registrations for some non-UK EU businesses

Under current (pre-brexit) UK VAT law, businesses that would ordinarily have to register for VAT purposes may avoid such a registration based on certain simplification measures, e.g. for call-off stock arrangements. In case the UK leaves the EU without a deal (Hard Brexit), these simplifications will no longer apply, resulting in immediate registration obligations.

Advance VAT registration.

In order to secure a smooth transition for supply chains in the event of a Hard Brexit, the British tax authorities (HMRC) have implemented a temporary possibility to register for VAT purposes in advance, even if no registration is required under current (pre-brexit) VAT law. The VAT registration will only become valid in case the UK exits the EU without a withdrawal agreement in place. Otherwise, registrations shall be amended or will be cancelled.

The Advance VAT registration is limited to businesses directly affected by a Hard Brexit because they would no longer be able to apply certain simplification measures. The British tax authorities (HMRC) have published an update of VAT Notice 700/1 containing guidance on Advance VAT registrations in chapter 4.7.

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