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HMRC internal manual

VAT Place of Supply (Goods)

HM Revenue & Customs
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Main rules: intra-EC movements: transfers of own goods

The transfer of goods within the same legal entity from one Member State to another is deemed to be a supply (see the manual covering the Single Market). The place of supply follows the normal rules for intra-EC movements of goods (see VATPOSG3810), so that where the goods are removed from the UK to another EC Member State the deemed supply takes place in the UK. Where the goods are removed to the UK from another Member state the deemed supply takes place outside the UK.

An example of a transfer of own goods is the movement of consignment stocks. This is the term used to describe goods transferred from one Member State to another to create a stock from which supplies may be made periodically as required (see the manual covering the Single Market). There is an initial deemed supply of own goods to form the stock which takes place in the Member State from which the goods are originally dispatched. The place of subsequent supplies of the goods, once a buyer has been found, is normally the Member State in which the stock is held.

In the UK an overseas supplier who has consignment stocks in the UK can, as an alternative to registering for VAT in UK, appoint an agent who is registered for VAT in the UK. The agent can then account for the UK acquisition VAT (on behalf of the overseas supplier) when the goods arrive in the UK. The agent also accounts for the VAT due on subsequent supplies. You can find out more about this in manual covering taxable persons.

A further example is goods supplied on a sale or return basis to a potential customer in another Member State. The place of supply is the Member State of dispatch. There is a further supply in the Member State of arrival if the goods are adopted there (see also the manual covering the Single Market).