Triangulation and other chain transactions

Produced by Tolley
Triangulation and other chain transactions

The following Value Added Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • Triangulation and other chain transactions
  • Typical triangulation transaction
  • Explanation
  • Requirements
  • Additional UK requirements for a non-UK intermediary selling to UK customers
  • Intermediaries who do not meet the triangulation requirements
  • Accounting requirements
  • UK supplier (A)
  • UK intermediate supplier
  • UK end customer
  • More...

Triangulation is an EU simplification measure that was introduced in order to reduce the requirement for businesses that enter into triangulation transactions to register for VAT in overseas jurisdictions.

Under the normal VAT rules, the intermediary party involved in a triangulation transaction would need to register for VAT in either the original supplier’s member state or the final customer’s member state in order to account for VAT on the transaction.

Triangulation is the term used to describe a chain of intra-EU supplies of goods involving three EU VAT registered businesses, VAT registered in different EU member states, where the goods go directly from the original supplier to the end customer.

Typical triangulation transaction

The following diagram demonstrates how a typical triangulation transaction is undertaken:

VATSM5215

Explanation

‘B’ (UK intermediary supplier) receives an order from ‘C’ (French final customer).

‘B’ places an order with ‘A’ (German original supplier) to fulfil the order. ‘A’ sends the goods direct to ‘C’ in France. Therefore the goods go direct from Germany to France.

The original supplier ‘A’ invoices ‘B’ for the goods and ‘B’ in turn invoices ‘C’ for the goods supplied.

The following rules apply to triangulation transactions taking place within the UK. The rules are broadly the same in all EU member states although certain EU member states can apply the rules more stringently.

Requirements

  1. all parties must be VAT registered in different EU member states. Non-EU vendors can be involved in triangulation transactions providing they are VAT registered in the relevant EU member state. If a non-EU vendor is the intermediary supplier (‘B’) they can be VAT registered in any EU member state except the member state where 'A' and 'C' are registered (see below)

  2. the goods must remain in the EU and the goods must move direct from the original supplier (‘A’) to the end customer in the chain (‘C’)

  3. only three parties can be involved in a triangulation transaction. If more than three parties are involved this is called a ‘chain transaction’ and

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