V4.303 Direct and indirect exports

It should be noted that there are separate definitions of 'direct export' and 'indirect export' for (a) VAT purposes, and (b) customs purposes. This division is only concerned with the VAT definitions. The customs definitions may be found at VEXP40300, and relate to the geographical route by which the goods leave the UK (ie direct from the UK, or via other EU member states prior to 1 January 2021).

Direct exports

HMRC indicates that a direct export occurs when a supplier sends goods to a destination outside the UK and is either responsible for arranging the transport itself or for appointing a freight agent1. Elsewhere it defines a direct export as when the complete transaction from supply to export is under the control of the UK supplier or owner of the goods2. Direct exports are to be contrasted with indirect exports (see 'Indirect exports' below).

The conditions attached to the zero-rating of direct exports are as follows3:

  1.  

    •     HMRC is satisfied that a person supplying goods has exported them to a place outside the UK (see V4.301 'Meaning of export')

  2.  

    •     such conditions (if any) specified in regulations are fulfilled

  3.  

    •     such conditions (if any) as HMRC may impose are fulfilled

Conditions specified in regulations for zero-rating direct exports

No regulations have been made to date.

Conditions imposed by HMRC for zero-rating direct exports

This provision gives statutory authority for the statement contained in Notice 703 that a supplier must export goods and obtain proof of export, within the time limits

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