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UK – GB to Northern Ireland IOSS EU e-commerce rules

E-commerce sales of goods to Northern Ireland (NI) from the rest of the UK (Great Britain or GB) now have special rules following the 1 July introduction of the EU’s e-commerce VAT package VAT. This may affect UK sellers who are EU IOSS registered selling goods not exceeding £135 (€150) to NI consumers.

The UK enacted its own version of the ecommerce VAT rules from 1 January 2021 at the end of the Brexit transition period. This meant that imported sales to UK consumers from overseas and not exceeding £135 (€150) were subject to UK VAT. Any overseas seller should charge this in the checkout and report through a UK VAT registration.

Northern Ireland VAT IOSS after 1 July 2021 EU e-commerce package

Since 1 July 2021, UK sellers selling to Northern Ireland consumers may now have to report certain sales through their EU Import One-Stop-Shop (IOSS) VAT filings.

Sales of consignment stocks not exceeding €150 imported from outside the EU to EU-resident consumers attract sales or output VAT since 1 July 2021. This is part of the EU’s e-commerce package of VAT reforms. Eligible sales may be reported in the new EU Import One-Stop-Shop (IOSS) return, covering all 27 member states.

Following the EU-UK Brexit Withdrawal Agreement and attached Northern Ireland Protocol, Northern Ireland holds a dual position in the UK and EU VAT regimes – as well as the customs unions of the EU and the UK.

UK sellers of imported consignments not exceeding £135 (€150) to NI consumers have two options for charging VAT to their customers:

  1. If they are IOSS registered for their sales to EU consumers, then they must (not optional) record consignments not exceeding €150 (£135) in value into Northern Ireland on their IOSS return. They must inform the UK’s HMRC now of their IOSS number and the EU state they have IOSS registered in (member state of identification). They will then charge UK VAT rates, declare the VAT in their IOSS monthly return in their member states of identification.
  2. If they are not IOSS registered, then they should continue to apply domestic UK VAT, and declare this through their regular quarterly UK VAT return

Intermediaries and Northern Ireland IOSS sales

Any EU Intermediary, acting for UK businesses selling consignments not exceeding €150 (£135) to NI must inform the UK’s HMRC of their IOSS registration number and details of the sellers they are representing. This requires a separate application notification for each seller they represent.

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