Who counts as a non-established taxable person
You are a NETP if your business has no UK establishment. HMRC's VAT Notice 700/1 (section 9) defines a NETP as "any person who does not have a UK establishment". A UK establishment exists only where essential management decisions and central administration happen in the UK, or where the business has a permanent physical presence in the UK with the people and equipment to make or receive supplies.
This catches more founders than they expect. A seller in Pakistan, India, Nigeria, the UAE or Bangladesh selling into the UK is a NETP. So, often, is a UK Ltd run entirely from abroad. HMRC's manual says "a company incorporated in the UK would not alone constitute a UK establishment": it looks at where the business is actually managed and run. A US LLC selling on Amazon UK is a NETP too.
Where your business is established is a judgment on facts. If you have UK staff, a UK office or a UK-based manager, get advice from a qualified UK tax adviser before deciding which rules apply.
No threshold: the 30-day rule
A UK-established business only has to register once taxable turnover passes £90,000. That threshold does not apply to NETPs. HMRC's manual says "NETPs must notify HMRC of their liability to be registered regardless of the value of the taxable supply".
The deadline is 30 days. Under GOV.UK's registration rules and section 9.3 of Notice 700/1, a NETP must register within 30 days of making a taxable supply in the UK, or within 30 days of first expecting to make one. A single UK sale can be enough. The £88,000 deregistration threshold does not help either: GOV.UK says it does not apply to businesses based outside the UK.
How the threshold works for UK-based businesses is covered in our guide to the VAT registration threshold.
Selling through Amazon, eBay and other online marketplaces
Since 1 January 2021, online marketplaces have been responsible for UK VAT on two kinds of sale by overseas sellers to consumers. HMRC's guidance on VAT and overseas goods sold using online marketplaces sets them out:
| Where the goods are at the point of sale | Who accounts for VAT on the sale to a UK consumer |
|---|---|
| Outside the UK, in a consignment worth £135 or less | The online marketplace |
| Already in the UK (for example in a marketplace fulfillment warehouse), sold by a seller not established in the UK | The online marketplace |
| Outside the UK, consignment worth more than £135 | Normal import rules: VAT is charged when the goods are imported |
| Any of the above, where the buyer is a VAT-registered business that gives its UK VAT number | The marketplace does not charge VAT; the seller or the business customer accounts for it, depending on the sale |
Goods already in the UK: the deemed supply
If your stock sits in a UK warehouse and a marketplace sells it for you, HMRC treats you as making a zero-rated supply of the goods to the marketplace, called a "deemed supply", and the marketplace makes the taxable sale to the customer. You do not issue VAT invoices for deemed supplies.
The catch is import VAT. HMRC's marketplace guidance says the overseas seller "will remain liable for any import VAT and Customs Duty when the goods are first imported into the UK." Shipping pallets to a UK fulfillment center is an import, and you are usually the importer.
Register, or apply for exemption from registration
An overseas seller whose only UK supplies are zero-rated deemed supplies has a choice. Section 12 of Notice 700/1 and HMRC's marketplace guidance say you can either register for VAT or apply for exemption from registration. The exemption is lost if the marketplace passes you the VAT details of a business customer, because that sale is no longer a zero-rated deemed supply.
Most sellers who import stock register anyway. HMRC's guidance says overseas sellers who are registered "can reclaim any import VAT they had to account for when the goods were first imported into the UK." Without a registration, the import VAT you paid is a cost you cannot recover.
The £135 value is the consignment value, not the value of each item. HMRC says the marketplace works it out from the "intrinsic value": the sale price, excluding transport, insurance and other identifiable taxes and charges.
Selling directly: your own website or social media
When you sell directly to UK consumers, no marketplace takes on the VAT, so it sits with you. HMRC's guidance on overseas goods sold directly to UK customers says:
- Consignments of £135 or less shipped from abroad: you charge and account for UK VAT at the point of sale, so you need a UK VAT registration. Import VAT is not charged at the border for these consignments.
- Consignments over £135: normal import VAT and customs rules apply when the goods arrive.
- Goods already in the UK when sold: you charge UK VAT on the sale and account for it on your VAT returns.
- Excise goods such as alcohol and tobacco are excluded from the £135 rules and follow separate procedures.
Many sellers do both: marketplace sales that the marketplace handles, plus a Shopify or similar store where they must charge VAT themselves. One VAT registration covers both.
Import VAT and postponed VAT accounting
Import VAT is generally charged at the same rate as VAT on the same goods sold in the UK, most often the standard rate of 20%. Without a VAT registration, it is paid in cash when the goods clear customs, usually through your courier or customs broker.
Once you are registered, you can use postponed VAT accounting. You declare the import VAT and reclaim it on the same VAT return, so no cash leaves the business at the border. The key points:
- Your business must be registered for VAT in the UK, and your VAT number goes on the import declaration.
- You need an EORI number, because import VAT is recorded against it.
- No approval is needed in advance. If a broker imports for you, tell them in writing that you want to use postponed accounting.
- HMRC issues monthly postponed import VAT statements that you use to complete your return.
Customs Duty is separate from VAT and is not postponed this way. Rates depend on the commodity code and origin of the goods.
VAT returns and Making Tax Digital
Registration brings regular returns. A return is due one calendar month and 7 days after the end of each period, normally quarterly, and the VAT must reach HMRC by the same date. A return is due even when there is nothing to pay.
Making Tax Digital for VAT applies to every VAT-registered business, NETPs included. VAT Notice 700/22 requires digital records in "functional compatible software" and digital links between any programs you use. For a marketplace seller, that means marketplace reports, import VAT statements and purchase invoices all feed into the software. Our VAT returns service covers the quarterly filing.
Do you need a UK VAT representative?
Usually not at the start. Section 10 of Notice 700/1 says appointing a VAT representative is optional. A representative must keep your VAT records and accounts and account for UK VAT on your behalf, so it takes on real responsibility for your UK VAT.
HMRC can change that. Notice 700/1 says HMRC "can direct you to appoint a VAT representative or ask you to pay a security", and a directed representative must be UK-based and meet "fit and proper" standards. If you receive a direction, act on it quickly and get professional advice.
How to register as a NETP: practical steps
NETPs register online through HMRC's VAT registration service, using the address of the principal place of business outside the UK (section 9.4 of Notice 700/1). HMRC charges no fee.
- Confirm you are a NETP. Check where the business is managed and whether it has any UK premises or staff. If in doubt, get advice.
- Fix your registration date. Identify the date of your first UK taxable supply, or the date you first expected one. The 30 days run from there.
- Gather business details. Legal name, company or registration number, principal place of business, directors or owners, bank details, a description of what you sell and your expected UK sales.
- Get an EORI number if you will import goods yourself.
- Apply online through a Government Gateway account and answer HMRC's questions on establishment, marketplace selling and imports.
- Reply to HMRC promptly. HMRC may ask for more evidence about the business. Slow replies delay the number.
- After registration, set up MTD software, add your VAT number to marketplace accounts and your own store, and diary each return deadline.
If you register late, you must still account for VAT from the date you should have been registered, even on sales where you charged no VAT, and HMRC can add a penalty. Our threshold guide explains late registration penalties.
Borderless Filings prepares and submits NETP registrations: we check your first-supply date, prepare the application from your documents, answer HMRC's follow-up questions with you and track the application in your portal. We cannot promise HMRC will register you or give a processing time, because HMRC does not publish one. Our VAT registration service has full details.
Things this guide does not cover
Northern Ireland has separate rules for goods moving to and from the EU. Sales of services and digital services to UK consumers follow different place-of-supply rules. Customs classification, duty rates and product safety rules are outside VAT altogether. If any of these apply, speak to a qualified adviser. If you also sell into the US, see our guide to US sales tax for Amazon sellers.
Sources
- HMRC: VAT Notice 700/1, Who should register for VAT
- HMRC manual: VATREG37050, non-established taxable persons
- HMRC manual: VATREG37150, UK establishment
- GOV.UK: VAT registration, when to register
- GOV.UK: How to register for VAT
- GOV.UK: Cancel your VAT registration
- HMRC: Increasing the VAT registration threshold
- HMRC: VAT and overseas goods sold to customers in the UK using online marketplaces
- HMRC: VAT and overseas goods sold directly to customers in the UK
- HMRC: Check when you can account for import VAT on your VAT Return
- GOV.UK: Get an EORI number
- GOV.UK: VAT rates
- GOV.UK: VAT Returns deadlines
- HMRC: VAT Notice 700/22, Making Tax Digital for VAT
Fees, deadlines and rules on this page were last checked on 27 September 2026.