Here is how to report sales of goods from Northern Ireland to VAT-registered customers in EU countries using the EC Sales List:
If you are a VAT-registered business in the UK and supply goods from Northern Ireland to VAT-registered customers in EU countries, you must report it to HMRC. You will need to use the European Community Sales List (EC Sales List) to show:
- Details of each of your EU customers,
- The value of goods supplied to them,
- The country code of the customer.
When to fill in the EC Sales List
You must complete the EC Sales List if you are trading from Northern Ireland and have done any of the following:
- Supplied goods from Northern Ireland to a VAT-registered business in the EU, even if no invoice was issued,
- Moved goods from Northern Ireland to a VAT-registered branch or subsidiary in an EU country,
- Issued a credit note to a customer in the EU for goods supplied from Northern Ireland,
- Sold goods to an EU customer and arranged the shipment directly through your EU supplier (triangular trade).
Zero VAT Rate Conditions
If you are supplying goods from Northern Ireland to VAT-registered customers in the EU, you can apply a zero VAT rate, provided that:
- Your customer is VAT-registered in an EU country and has provided you with their VAT number,
- The goods have been sent or transported from Northern Ireland to the destination in the EU country.
Filling in the EC Sales List Form
In the EC Sales List form, you need to provide:
- The country code of the customer,
- The customer’s VAT number,
- The total value of supplies to each customer.
Deadline for Submitting the EC Sales List
You must submit the EC Sales List within 21 days after the end of the reporting period. If you delay the submission, you may be penalized for late filing.
Movement of Goods Under Call-Off Stock Arrangements
If you are moving goods from Northern Ireland to the EU under call-off stock arrangements, you must add the following details to your EC Sales List:
- The transport of the goods to the intended customer (VAT-registered businesses in the EU),
- Any change in the intended customer for call-off stock,
- The return of any call-off stock to Northern Ireland.
You must keep a register with details of the call-off stock movements and their values.
The EC Sales List form should include:
- The country code of the intended customer (2-letter code),
- The customer’s VAT number in the first field,
- For the transport of goods, use the code “4” in the indicator column,
- Leave the “Total value of supplies” and “Second VAT number” fields blank.
You must also record any returned call-off stock within 12 months of arrival in the EU. This includes:
- The period during which the goods were returned,
- Record the return of the goods in your register.
Return of Call-Off Stock to Northern Ireland
If you return call-off stock to Northern Ireland without it being sold, you must include the following information on the EC Sales List for the relevant period:
- The customer’s country code,
- The customer’s VAT number in the first field,
- The code “5” for returned stock in the indicator column,
- Leave the “Total value of supplies” and “Second VAT number” fields blank.
Change of Intended Customer
If there is a change in the intended customer within 12 months of the goods arriving in the EU, you must update your register and include the following on your EC Sales List for that period:
- The country code of the original customer,
- The VAT number of the original customer in the first field,
- The VAT number of the new customer in the second field,
- The code “6” in the indicator column to indicate the change.
For changes in the intended customer, do not enter the value of the goods on your EC Sales List.
Sale of Call-Off Stock
When call-off stock is sold (the sale occurs), it must be reported the same way as any other sale of goods from Northern Ireland to a VAT-registered business in the EU. You must record this on your VAT return for the period when the supply was made.
This means that if call-off stock was moved from Northern Ireland to the intended customer in an EU country and sold in the same period, you must:
- Record the movement of call-off stock in your EC Sales List for the period,
- On a separate line, record the sale of goods to that customer.
If call-off stock is not sold within 12 months of arrival in the destination EU country, it must be treated as being supplied to yourself in the destination country and reported as a sale (dispatch) on your EC Sales List.
Relevant Events for Call-Off Stock
When certain events (relevant events) occur regarding call-off stock, the stock is treated as being supplied to yourself in the EU country and must be reported as a sale (dispatch) on your EC Sales List.
Checking EU VAT Numbers
You must verify your customer’s VAT number to confirm they are VAT-registered in the EU. You can:
- Contact your customer if they have not provided you with a VAT number or if you think the one they gave is incorrect,
- Ask them for their VAT number in your language,
- Ensure the VAT number they gave you is in the correct format for their country,
- Use the VIES system to check if the VAT number, name, and address are valid— you can also get a certificate of verification.
You must do this for new customers.
Calculating Total Supplies to a Customer
Add up the value of all goods supplied in the period, rounding down to the nearest whole pound. Enter a separate line for each customer and type of supply. The values for goods supplied from Northern Ireland to each customer include:
- Costs like delivery charges, whether you charged them or not, minus any credit notes issued,
- Goods moved from Northern Ireland to your own VAT-registered branch, office, or subsidiary in the EU,
- Any triangular supplies of goods on a separate line using code “2” in the indicator column,
- Credit notes issued without making any supplies, using a negative sign before the amount.
Do not include the value of goods that:
- Have been sent for processing,
- Qualify as samples under VAT rules.
If you are moving goods from Northern Ireland to the EU under call-off stock arrangements, there are several obligations that must be met to correctly report these transactions. Movements of goods, changes in the intended customer, returns, and other relevant events must be carefully recorded in the EC Sales List, which must be submitted to HMRC. Additionally, it is important to verify your customers’ VAT numbers and accurately calculate the value of supplies, taking into account various costs and types of transactions.
Correct reporting and verification of all goods movements and transactions with EU customers help avoid VAT issues and ensures compliance with EU regulations. Remember to regularly update your register and documentation, as well as meet the submission deadlines for the EC Sales List to avoid penalties and tax-related issues.