Brexit no deal? VAT issues to consider

As the Brexit deadline approaches and the likelihood of a deal which can pass through the House of Commons still remote, businesses are left with no choice but to plan for a no deal situation from 29 March 2019.

No deal means that the UK will revert to being a "third country" under EU law, with no trade deal or other trading arrangements in place with the EU.

All UK businesses which trade in goods with the EU will need to take steps to address the compliance and logistics issues which a no deal will cause. There are also direct tax implications for UK businesses with subsidiaries or affiliates in the other EU27 states. (Export documentation and processes remain the same for all countries outside the EU.)

In addition, there are specific regulatory issues applying to certain industries and sectors (such as pharmaceuticals, fisheries and food) which may need detailed consideration and action.

Checklist - VAT issues to consider
If you are due to make a refund claim for VAT incurred in other EU member states during 2018, this needs to be done in advance of 29 March as it is likely that the claims process will change if there is a no deal Brexit. (HMRC details here)
If you have a MOSS registration to account for VAT on supplies of electronic services to EU consumers you will need to take action if there is a no deal Brexit. If you will continue to sell electronic services to EU consumers you will need to register for the VAT MOSS non union scheme in a continuing EU member state. You can only do this after the UK has left the EU if this is the case on 29 March, and a new registration for sales between 29 and 31 March will need to be in place by 10 April.

Please contact us for advice if you feel you will be affected by a no-deal Brexit.