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HMRC internal manual

VAT Place of Supply (Goods)

From
HM Revenue & Customs
Updated
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Gas and electricity: Impact on suppliers

Wholesale supplies

It is important to remember that, for wholesale supplies, the actual location of the electricity is immaterial. What follows therefore applies to electricity wherever it might be located in the world. For natural gas it applies to the extent that the gas is in a natural gas system either located within the EU, or linked to a system within the EU

UK Supplier

Customer established in UK Customer established in another Member State Customer established outside the EC
     
The supply takes place in the UK and is liable to UK VAT. The place of supply is the EU Member State in which the customer’s business is established.  

If the customer is VAT registered they will account for the VAT due as a reverse-charge (see VATPOSG5700).

If the customer is not VAT-registered, the supplier may need to register for VAT in that Member State and account for VAT there. The place of supply is outside the EU and therefore outside the scope of EU VAT.

Overseas supplier

A wholesale supply by an overseas supplier to a customer established in the UK takes place, and is liable to VAT, in the UK. If the UK customer is registered for VAT, they will account for the VAT due as a reverse-charge (see VATPOSG5700). In the unlikely event of the customer not being registered for VAT, the supplier may be required to register here. 

Supplies for consumption

The results here are dictated by the place of consumption.

UK suppliers

Consumption in the UK Consumption in another Member State Consumption outside the EC
     
The supply takes place in the UK and is liable to UK VAT. The place of supply is the EU Member State of consumption.  

If the customer is VAT-registered in the Member State of consumption they will account for the VAT due as a reverse-charge (see VATPOSG5700).

If the customer is not VAT-registered, the supplier may need to register for VAT in that Member State and account for VAT there. The place of supply is outside the EU and therefore outside the scope of EU VAT.

Overseas suppliers

A supply by an overseas supplier to a customer consuming natural gas or electricity in the UK takes place, and is liable to VAT, in the UK. If the UK customer is registered for VAT, they will account for the VAT due as a reverse-charge (see VATPOSG5700). However, if the customer not registered for VAT the supplier may be required to register here.