HMRC internal manual

VAT Traders’ Records Manual

VATREC5020 - VAT invoice: VAT invoices for intra-EC supplies

The obligation to provide a VAT invoice for intra-EC supplies is covered by VAT Regulations 1995, regulation 13(1)(b). The details which must be shown on the invoice are listed in VAT Regulations 1995, regulation 14(2):

14 - (2) Save as the Commissioners may otherwise allow, where a registered person provides a person in another member State with a VAT invoice or any document that refers to a VAT invoice and is intended to amend it, he must ensure that it states thereon the following particulars-

  1. the information specified in sub-paragraphs (a) to (e) (g) (j) (m) (n) and (o) of paragraph (1) above,*
  2. the letters “GB” as a prefix to his registration number,
  3. the registration number, if any, of the recipient of the supply of goods or services and which registration number, if any, shall contain the alphabetical code of the member State in which that recipient is registered,
  4. the gross amount payable, excluding VAT,
  5. where the supply is of a new means of transport (as defined in section 95 of the Act) a description sufficient to identify it as such,
  6. for each description, the quantity of the goods or the extent of the services, and where a positive rate of VAT is chargeable, the rate of VAT and the amount payable, excluding VAT, expressed in sterling, and
  7. where the supply of goods is a taxable supply, the information as specified in sub paragraph (l) of paragraph (1)* and
  8. where the supply is an exempt or zero-rated supply, a relevant reference or any indication that the supply is exempt or zero-rated as appropriate.**

*(Note: this refers to regulation 14(1) - see paragraph 5.1)

**Item (h) in regulation 14(2) was inserted by SI2085/2007, regulation 7(e), operative from 1 October 2007.

There are special arrangements for certain types of business. See 16000

Requirement to include a sequential number

Previously, the wording of regulation 14(1)(a) stated only that the invoice required ‘an identifying number’. Now, 14(1)(a) requires “a sequential number based on one or more series which uniquely identifies the document.”

Consultation with businesses prior to the change of wording confirmed that the new wording has no effect on the way that the majority of businesses number their invoices, as they already issue invoices from a sequential series.

The change has resulted in questions from business and their advisors, and a summary of the more common questions and answers is provided below:

Does the invoice number series have to be numerical, or can it include letters?

The ‘invoice number’ can be numerical, or it can be a combination of numbers and letters, as long as it forms part of a unique and sequential series.

In order to avoid the appearance of having only just started in business I do not want to start at Invoice no.1 and would prefer to commence with, say, Invoice no 1135. Is this allowed?

Yes, as long as the invoice series runs consecutively from that point.

I currently use a unique customer reference number as the identifying number on the invoice. If I add an additional consecutive number will this be acceptable?

Yes, this would have the affect of creating a unique and sequential series.

I have several customers and I wish to run several separate sequences of invoices at the same time. Is this possible?

Yes, it is acceptable to operate more than one sequence at the same time.

My business operates as several separate business units or divisions. Is it possible for each unit or division to operate its own sequence of invoices?

Yes, it is acceptable to operate more than one sequence at the same time.

I operate a service centre, centrally issuing invoices from one series covering several corporate group companies situated in several EC member States. This means that there will be apparent breaks in invoicing sequence for each company, but I can show that the invoices are issued in sequence, albeit allocated to different entities. Is this acceptable?

Yes, this satisfies the requirement for invoices to be issued sequentially from one or more series.

What if there is a break in sequence, for example where I cancel an invoice or it is spoiled and never issued to a customer?

As long as you retain the cancelled or spoiled invoice in your accounting records, or you can provide an explanation for the break in sequence, this is acceptable.