Guides / UK VAT registration for EU businesses · Updated 30 September 2026

UK VAT registration for EU businesses: when it is required

EU businesses without a UK establishment have no VAT threshold in the UK. Here is when registration is required, how marketplaces change it and how to register.

This guide is also available in Polish.

Many EU businesses assume UK VAT works like the domestic regime at home: nothing to do until sales pass a threshold. For a business with no establishment in the UK that assumption is wrong, and it is one of the most common reasons Polish and other EU sellers end up registering late. This guide explains, using HMRC's own guidance, when a business based in the EU has to register for UK VAT, how marketplaces change the picture, and what registration involves.

Are you a non-established taxable person?

HMRC uses the term non-established taxable person (NETP). According to VAT Notice 700/1, a NETP is any person who does not have a UK establishment. A business has a UK establishment where its essential management decisions and central administration happen in the UK, or where it has a permanent physical presence in the UK with the human and technical resources to make or receive taxable supplies.

In practice, a Polish company run from Poland that sends goods to British customers, holds stock in a UK warehouse, or sells through a UK marketplace, but has no office and staff in the UK, will usually be a NETP. Having stock sitting in a third-party fulfilment centre does not by itself give you the management and human resources that the establishment test describes.

No threshold for NETPs

This is the key point. The general UK VAT registration threshold (stated on GOV.UK as £90,000 of taxable turnover) is for UK-established businesses. Notice 700/1 is explicit that for a NETP the registration threshold for taxable supplies does not apply, so you have to register if you make taxable supplies of any value in the UK. The GOV.UK "Register for VAT" page says the same: a business based outside the UK must register, regardless of taxable turnover, if it supplies goods or services to the UK or expects to in the next 30 days.

If you have read that EU sellers only need UK VAT registration once UK sales exceed a turnover figure, check the source. For a business without a UK establishment, HMRC's guidance says the threshold does not apply.

Deadline

Notice 700/1 says a NETP must tell HMRC within 30 days of the date of making a taxable supply in the UK, or within 30 days of the date it expects to make one. Registering late does not remove the VAT that was due on earlier sales.

Typical situations for EU businesses

Selling goods that are already in the UK

If you hold stock in the UK and sell it to UK customers directly (your own web shop, phone orders, sales to trade buyers), the sale is a UK supply and, as a NETP, you are within the registration rules from the first sale.

Importing goods into the UK yourself

When you move goods from the EU into UK stock, someone has to be the importer and deal with the import declaration, customs duty and import VAT. HMRC's marketplace guidance states that the overseas seller remains liable for any import VAT and customs duty when goods are first imported into the UK, and that registered overseas sellers can reclaim the import VAT they had to account for under the normal input tax rules. If you act as importer, you will also need an EORI number, and the import declaration is lodged in CDS, usually through a customs agent. If you want to account for import VAT on your return instead of paying it at the border, see our guide to postponed VAT accounting.

Selling through an online marketplace

Marketplaces change who accounts for VAT on the sale, not always whether you must register. HMRC's guidance for overseas goods sold through online marketplaces says:

for goods located in the UK at the point of sale, the marketplace is liable to account for the VAT on sales made through it by a seller not established in the UK;
for imported consignments of £135 or less, the marketplace must charge and account for VAT at the point of sale, unless it is a business-to-business sale where the buyer has given a VAT registration number;
where the marketplace handles the VAT on a sale of goods already in the UK, the seller is treated as making a zero-rated supply to the marketplace.

An overseas seller whose only UK supplies are those zero-rated deemed supplies can either register or apply for exemption from registration. Sellers making business-to-business sales, however, must register and account for VAT on those sales. And because the seller who imports stock remains liable for import VAT and duty at the border, most EU sellers who ship their own stock into UK fulfilment centres register in order to reclaim that import VAT.

Selling only goods that are outside the UK

HMRC's guidance on overseas goods sold directly to UK customers indicates that sellers do not have to register if they only sell goods that are outside the UK at the time of sale to UK VAT-registered businesses that account for VAT under the reverse charge. The customer then deals with the import. This is where delivery terms matter: our guide on Incoterms and who clears customs explains how the choice of term decides who acts as importer.

How to register

Notice 700/1 says a NETP can register using HMRC's online VAT registration service, giving its principal place of business, which must be outside the UK. GOV.UK also explains that you can appoint an accountant or agent to register and deal with HMRC on your behalf. Once registered, HMRC sends:

a 9-digit VAT registration number, which must appear on your VAT invoices;
information on setting up your business tax account;
the date your first VAT Return is due;
your effective date of registration.

Keep the effective date in mind: if it is earlier than the date you applied, you are responsible for VAT on supplies made from that date.

Do you need a fiscal representative?

Not automatically. According to Notice 700/1, appointing a VAT representative is optional unless HMRC directs you to appoint one. A VAT representative is jointly and severally liable with you for your VAT debts, which is why representatives often ask for security. An agent or accountant who simply files returns and corresponds with HMRC for you is a different, lighter arrangement. Claims that every non-UK business must appoint a fiscal representative before registering do not match HMRC's guidance.

Practical checklist

Confirm whether you have a UK establishment under the Notice 700/1 test.
List every UK supply you make or expect to make in the next 30 days, including sales from UK stock and B2B sales.
Decide who will be the importer of record and get an EORI number if it is you.
Check which sales run through a marketplace that accounts for the VAT, and which do not.
Register within 30 days of the first taxable UK supply.
Decide whether you need a VAT representative, an agent, or neither.

For a view aimed specifically at Polish companies, Easy Clearance publishes an overview of UK VAT registration steps for Polish companies. For the customs side of importing, see do you need a customs broker?

Related guides

Importing into the UK from Poland or the EU?

Easy Clearance is a UK–EU customs clearance agency handling import and export declarations, T1/T2 transit and UK–Poland removals. Its article covers UK VAT registration for Polish companies.

Read the Easy Clearance article

Sources

General information, not legal, tax or customs advice. Rules change; confirm current requirements on gov.uk or with a registered agent before you ship.