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HMRC internal manual

VAT Registration

Non-established taxable persons (NETPs): requirement to appoint a VAT representative

The Department has the power under the VAT Act 1994, section 48(1) to direct an NETP whose business is not established in the EU to appoint a VAT representative.


Once appointed, the VAT Representative is responsible to the same extent as the taxable person for all aspects of the taxable person’s VAT affairs including liability for VAT.


This power was strengthened as part of a package of measures introduced in Finance Bill 2016 to tackle VAT evasion through online sales.


From 7 November 2016, the Department has the power to direct an NETP which has no EU establishment to appoint a VAT representative who

  • is established in the UK, and
  • is fit and proper (see VATREG37410).


You should only agree to the appointment of a particular individual in the capacity of a VAT Representative if you are confident that they will be able to, if necessary, meet their principal’s VAT debts. (It is likely that anybody acting as a VAT Representative will need to have taken out some form of financial protection.)


From 13th October 2016, the Department may choose to require some form of security from a taxable person who is not established in the UK whether or not there has been any direction regarding the appointment of a VAT representative.