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HMRC internal manual

VAT Time of supply

Tax points for specific types of supply: Intra-EC supplies of goods


Within the Single Market there are special VAT rules for supplies between Member States. Prior to the Single Market, supplies involving the removal of goods from the UK were all treated as exports regardless of destination. Export arrangements still apply to goods bound for third countries and these remain subject to the normal domestic time of supply rules.

Supplies to non-VAT registered persons

Intra-EC supplies may only be zero-rated in circumstances where they are made to another VAT registered person. Supplies of goods delivered to non-VAT registered persons in another Member State are liable to VAT in the Member State of departure. Supplies of this kind made from the UK are subject to the domestic time of supply rules.

Supplies to VAT registered persons

Under section 6(7) and(8) of the VAT Act 1994 (see VATTOS2240) there are special time of supply rules for goods removed to another EC Member State under the arrangements that allow the supply to be zero-rated in the UK. Essentially this covers supplies to VAT registered customers in other Member States where the customer is subject to acquisition procedures in the Member State of arrival. The tax point is the earlier of the following times

  • the fifteenth day of the month following the one in which the goods are sent to the customer or the customer collects them, or
  • the date of issue of the VAT invoice.

In considering these rules it is worth remembering that the date of despatch, or collection, will normally correspond to the basic removal tax point under UK domestic rules. Further more, an invoice issued in these circumstances represents a VAT invoice even though it is for a zero-rated supply. This is because regulations 13 and 14 of the VAT Regulations 1995 make specific provision for this.

This latter point is especially important for intra-EC supplies falling within regulation 86 (see VATTOS2340). Single market rules preclude payment tax points for intra-EC supplies. Therefore, under regulation 86(5), the tax point for supplies to other Member States is restricted to the date of issue of the VAT invoice.