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HMRC internal manual

VAT Export and Removal of Goods from the UK

Assurance procedures: evidence of export and removal and time limits

In order to zero rate a supply of goods exported to a non-EU country or removed to another Member State, the supplier must meet time limits for export or removal and must keep evidence to prove that the goods have reached their destination. This section sets out several problem areas often encountered during assurance interventions and any action you should take.

Problem area …. Possible action to take ….
Trader does not know what evidence of export or removal is required or the relevant time limits. In such circumstances you should advise the trader that for exports evidence can be either official or commercial. For removals it is only commercial. Details of what constitutes evidence and when it must be obtained are discussed elsewhere in this section, and in VEXP30400, and Notices 703 and 725. The evidence must not only show that a sale has taken place but also that the goods have been removed from the EU in the case of exports or the UK in the case of removals.
The trader must understand what this evidence is and that it must be obtained within the appropriate time limits. Establish whether the trader has a system in place to obtain this evidence and match it to the appropriate sales invoices in order to meet the conditions for zero rating the supply.    
  Evidence is not obtained within the appropriate time limits. Ask what the trader does if the evidence is not obtained within the appropriate time limits and whether any adjustment is made in the records to account for VAT on the supply because the requirements are not met. Check whether this is being done.
  Lack of communication between different areas of the business. Experience of checking exports and removals has shown that this evidence can be in a number of different sections within the business, and that these sections do not always know the requirements or communicate with each other. For example the sales invoices will be with the sales ledger department and the proof will be in the transport department. You will need to establish this at the start in order to avoid wasting time later in your visit.
  Evidence is not matched to sales. You may find that the trader has no system of matching evidence to sales in place but that all the evidence is held almost inadvertently. This is not satisfactory and the trader must be made aware that they are responsible for ensuring that the conditions for zero rating are met, and that failure to do so can result in assessments being raised.
Any lack of compliance must be considered and addressed. Failure to do so is unfair to other traders who bear the cost of being compliant.    
  Customer’s EU VAT registration number In the case of intra-EU removals you should also establish what steps the trader takes in order to check the validity of the EU customer’s VAT registration number.