Q1 When does the seller have no VAT registration obligation?

Amber：Under the new UK tax changes, companies outside the UK sell through the OMP platform, and when the sale takes place, goods are stored in a non-UK country and shipped from outside the UK to UK consumers（That's what we call it Straight hair packets）,No matter what the value is（Is there any single consignment over ￡135 per unit),Sellers are not obliged to register VAT.

* This can be verified by the fact that when the UK VAT is registered, the IRS refuses to issue the VAT number to the direct sellers who sell through OMP platform for foreign enterprises.

Q2 Why is it said that there is OMP platform involved in sales, but sellers of goods directly delivered outside the UK have no VAT registration obligation?

Amber：After the New Deal, for the single Consignment goods (Consignment direct goods) from the overseas of the UK under 135 pounds entering the UK, OMP platform participates in the sales (such as eBay, Amazon),No import VAT and import duty,Instead, it is levied at the "point of sale" output tax（Supply VAT）, The OMP sales platform withholds and pays the VAT.

* Here's the point, but the IRS doesn't require the sales platform to pay for direct shipments over £135! For shipments exceeding ￡135, there will still be an import VAT and duty, which will be levied on the import as before.

Q3 If a single consignment of goods exceeds 135 pounds, the seller has no VAT registration obligation, who is responsible for paying and collecting taxes?

Amber：British consumers or logistics companies, based on the policies of eBay and Amazon in favor of consumers, are most likely to collect and pay import VAT and customs duties on behalf of logistics companies, and this part of VAT input will be declared and paid by logistics companies.

Q4 Are there any loopholes and hidden dangers in the tax reform?

AMB believes that the UK's reform in customs clearance is to provide convenience for importers of small and medium-sized enterprises and achieve green customs clearance. Different from the previous application for customs clearance deferral, the previous application process was only friendly to the local large enterprises in the UK, and small and medium-sized enterprises could not apply for customs clearance deferral basically due to the lack of bank guarantee. Therefore, the green customs clearance realized now, by postponing the payment link of import VAT, can win more benefits for small and medium-sized enterprisesCash flow。

But the move also comes with potential consequences Tax fraud risk,This risk has also triggered heated discussions in the UK local financial forums. The existing input tax deduction link will be regulated by the HMRC penalty department for unreasonable input tax returns. However, after the tax reform, some tax experts pointed out that because of the integration of import customs clearance and VAT declaration,then HMRC And the customsIn the input tax The degree of control will be greatly weakened.

Q5Under the new tax reform in the UK, we participate in sales through OMP. What is the general situation that the tax bureau does not force the sales platform to withhold and pay VAT?

Amber：There are two main situations.

1. Sellers whose goods are outside the UK and whose value of a single item is more than £135;

2. The goods are stored in the UK and the seller of a local incorporated company in the UK.

Q6 How should a business-to-business transaction (B2B) be reported?

Amber：In the case of B2B, UK corporate buyers can provide their valid VAT number to UK overseas sellers or UK sales platforms, and the obligation to declare VAT is transferred to UK corporate buyers; The sale will be marked by Reverse Charge（Reverse VAT taxation）(E-commerce platforms will not withhold taxes for B2B orders, but overseas sellers still need to declare B2B).

Q7 What is reverse VAT taxation?

Amber：Reverse Charge (Reverse VAT levy) is a simplified procedure whereby the buyer is responsible for filing VAT, thus avoiding the hassle of international sellers registering VAT in the buyer's home country, also known as the "Reverse Charge"Tax transfer. Reverse Charge Only applicable to trade in services and B2B,Not applicable to goods trade and B2C.

Q8 What is the difference in the declaration of goods in the import link for UK FBA or UK Overseas Warehouse?

Amber：In this tax reform, the British customs should introduce a receiving address record method to identify whether the address of the single shipment belongs to the address of the British overseas warehouse or the private address of the British consumers.

The original destination for the overseas warehouse address, regardless of the value of the goods (whether more than £135), will be required to pay the import VAT and customs duty at the time of entry, the tax authority will usually send to the tax agent C79 (VAT summary certificate), to prove the actual amount of VAT paid in the month. However, the most significant change in this new policy is the introduction of "conference-vat Accounting""Customs clearance VAT deferral".

According to the new regulation in January 2021, importers can use "VAT deferred conferences for customs clearance". As the name implies, it means importer“No longer need”Import VAT should be paid when the goods enter the customs, but it can be filled directly in the sales VAT declaration, that is, the tax payment link is transferred from the customs clearance point to the VAT declaration point. If the seller imports the goods for sales, it will not be refunded or paid.

The tax bureau will send an electronic statement to the importer every month（Online Monthly Statement), Used as a comparison to fill in the delayed VAT（Postponed Import VAT）。

Q9 After the tax reform in the UK, has the tax bureau abolished the Flat VAT low rate?

Amber：At present, HMRC official website does not cancel the update of low Flat VAT tax rate for local companies in the UK or companies outside the UK, but because the goods are stored in non-UK enterprises in the UK), they are sold through OMP platform, and the VAT of the sales items are withheld and paid by OMP. According to the sales volume of OMP, it does not meet the tax standard of Flat VAT (the annual total sales volume is less than 15W pounds for application, and the accumulative annual declaration is over 23W pounds for withdrawal).

Therefore, flat VAT is no longer suitable for the application of overseas enterprises withheld and paid by OMP. However, if it is a British local enterprise, it is not within the scope of this tax reform (it is not subject to OMP withholding VAT). If it is a British local enterprise in line with the sales volume category of Flat VAT, it can continue to use Flat VAT to declare and pay VAT by itself.