Commentary

V3.358A Approval and registration of imported goods fulfilment businesses (with effect from 1 April 2019)

Part V3 Supplies, acquisitions and imports

V3.358A Approval and registration of imported goods fulfilment businesses (with effect from 1 April 2019)

V3.358A Approval and registration of imported goods fulfilment businesses1 (with effect from 1 April 2019)

As part of a package of measures to improve the VAT compliance of non-UK traders who make supplies in the UK of imported goods via 'fulfilment businesses', it was proposed that an approval/registration scheme be introduced for fulfilment businesses as a condition of their acting for non-UK traders. The proposal was subject to consultation2, and the relevant provisions were introduced in F(No 2)A 20173, and are described below. They are supplemented by regulations4 made under F(No 2)A 2017, ss 51 and 57. They came into effect on 1 April 2018 (with the exception of Part 3 (obligations and restrictions) and Part 4 (penalties) which came into force on 1 April 2019. However, Part 4 came into effect from 1 April 2018 in respect of penalties relating to a contravention of the rules regarding the dates by which an application for approval must be made5).

Other measures to improve the compliance of non-UK traders within the same package included giving HMRC power to direct that a UK representative be appointed as described at V2.115, and the power to make the operator of online marketplace joint and severally liable for the VAT debts of such traders as described at V3.502.

Note that where B2C goods sold by an overseas seller are in the UK at the point of sale and the goods are sold through an online marketplace, UK VAT is due at the time the sale of

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