Three schemes launched on 1 July will deal with VAT on business-to-consumer supplies of goods and services to EU customers.

They are known as the ‘Union’, ‘non-Union’ and ‘import’ schemes. The schemes are designed to facilitate the collection of VAT by one EU member state, which is then passed on to the member state in which the supply is deemed to take place.

The ‘Union scheme’ covers intra-EU supplies of goods and services for businesses with their place of business or a fixed establishment within the EU.

The Union scheme will also allow a UK business to hold stock within the EU (for example, the Netherlands) and pay VAT for all EU sales to the relevant tax authorities.

The ‘non-Union scheme’ covers supplies of services to EU customers by businesses with no establishment within the EU.

The ‘import scheme’ covers the distance sale of goods below €150 fulfilled from stock held outside the EU.

If businesses register for VAT using one of these schemes, they will complete one return for all EU sales, rather than being required to register for VAT in all member states in which their customers are based. These schemes will allow businesses to declare sales across all EU member states.

 Union Scheme/OSSNon-Union Scheme/OSSImport Scheme/ IOSS
Types of suppliesa) ALL B2C supplies of services in the EU
b) Distance sales of goods within the EU
c) Art 14a(2) domestic B2C supplies of goods
ALL B2C supplies of services to customers in the EUDistance sales of imported goods in consignments ≤ EUR 150.
Taxable persona) Only EU established
b) EU & non-EU established
c) Electronic interfaces
Non-EU establishedEU & non-EU established, including electronic interfaces 

“It will take time for VAT registered businesses to adapt to post Brexit VAT rules. The new schemes will allow businesses to understand which rules are applicable to their trade and therefore adapt accordingly.”

Nigel Holland