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HMRC internal manual

VAT Single Market

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HM Revenue & Customs
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Simplifications: triangulation: situations that fall within the normal rules

Introduction

Triangulation involving two parties registered in the same Member State is adequately covered by the normal rules for intra- EC supplies and acquisitions. For example, where the first supplier and intermediate supplier, or intermediate supplier and final customer are registered for VAT in the same Member State, the supply between the two can represent a domestic supply in the Member State in which they are both registered. The other supply may then be treated as the intra-EC removal. This is illustrated as follows.

First supplier and intermediate supplier registered in the same Member State

Use this link to view Triangulation normal rules 1 diagram

The result is a supply by

  • UK Co (1) to UK Co (2) that takes place in the UK and is subject to UK VAT, and
  • a zero-rated intra-EC supply by UK Co (2) to French Co, with an acquisition by French Co in France.

Intermediate supplier and customer registered in the same Member State

Use this link to view Triangulation normal rules 2 diagram

The result is a

  • zero-rated intra-EC supply by UK Co to French Co (1), with an acquisition by French Co (1) in France, and
  • a supply by French Co (1) to French Co (2) that takes place in France and is subject to French domestic VAT rules.

Goods remaining in the same Member State

Use this link to view Triangulation normal rules 3 diagram

Goods sent from first supplier to the final customer in the same Member State will represent two domestic supplies in the Member State in which the goods are located. In this example both supplies (between the first supplier and the intermediate supplier, and the intermediate supplier and the final customer) will take place in the UK. The French intermediate supplier may therefore be required to register for VAT in the UK.