Can a UK company still use the €10,000 EU VAT threshold after Brexit?

Not in the same way as an EU-established business. The threshold applies only if the supplier is established, or otherwise has a permanent address or usually resides, in a single EU Member State, and only to qualifying intra-Community supplies from that State. A company established only in the United Kingdom does not meet that condition.

Do I need EU VAT registration if I only ship from Great Britain?

Direct exports from Great Britain do not, on their own, create the same local registration duty as holding stock in the customer's country. EU import VAT still applies, and IOSS or the customs process may be relevant. Once you store goods in an EU country, a local VAT registration there is generally required.

If I use Amazon FBA in the EU, what VAT registrations do I need?

You generally need a VAT number in each EU country where Amazon stores your stock. You may then use Union OSS for qualifying sales to consumers in other Member States. OSS does not replace the local numbers. See our Amazon FBA VAT guide.

Can a UK company use OSS?

Yes, in the right circumstances, but not as a way to stay under the €10,000 intra-EU threshold from Great Britain. A non-EU business can use Union OSS for intra-Community distance sales from stock already in the EU. For B2C services supplied from the UK, GOV.UK says you can register for the non-Union OSS. IOSS requires an EU-established intermediary for a non-EU seller. PanVAT does not act as that intermediary.

How is Northern Ireland different, and is a fiscal representative always required?

Sales of goods from Northern Ireland to EU consumers are not treated as Great Britain exports. If those sales exceed £8,818, GOV.UK says you must pay VAT in the destination countries and can use the Union OSS or register in each country of supply. A fiscal representative is not required in every EU country. France, Italy and Spain generally require one for non-EU businesses, with listed exceptions; Germany generally does not, for ordinary taxable sellers. See our fiscal representative article.

EU VAT Registration for UK Companies after Brexit

About 6 minutes to read · Rules checked against the European Commission and GOV.UK on 12 November 2026

Short answer: From 1 January 2021, a company established in Great Britain is treated as a non-EU business for EU VAT. Goods shipped from Great Britain to the EU are generally UK exports — often zero-rated for UK VAT if you keep the required evidence — and they are imports into the EU. The EU-wide €10,000 distance-selling threshold applies only to businesses established in a single EU Member State, and only to qualifying intra-Community supplies from that State. A typical UK company is not EU-established, so it cannot use that threshold in the same way. If you store goods in an EU country, you generally need a local VAT registration there. You may then use the Union One-Stop Shop (OSS) from an EU Member State for qualifying sales of those goods to consumers in other Member States. Some countries also require a fiscal representative.

This guide explains EU VAT registration for UK companies after Brexit. It is not a substitute for OSS versus local VAT registration, and it does not repeat the legal rules in Do you need a fiscal representative for EU VAT?. For our services, see OSS registration and returns and fiscal representation.

Who PanVAT serves

PanVAT is a UK VAT compliance firm for eCommerce sellers, founded in 2019 by Touseef Aslam, Fellow of the Association of Chartered Certified Accountants (FCCA). We handle UK and EU VAT registration and returns fully remotely, through a network of local accountants in the United Kingdom, Germany, France, Spain, Italy, Poland, the Czech Republic, Austria and Ireland, with one point of contact.

What changed on 1 January 2021

HMRC guidance states that, from 1 January 2021, the VAT rules for movements of goods between Great Britain (England, Scotland and Wales) and the EU are the same as those for transactions with countries outside the EU, with some exceptions. Sales to EU business customers, previously treated as dispatches, became exports. Sales to EU consumers also became exports. For UK VAT, the supply can continue to be zero-rated if you keep evidence of the movement, and you no longer complete an EC Sales List for these supplies. GOV.UK says you do not normally need to charge VAT on goods sold to customers outside the UK; you only need to be registered with HMRC and can zero-rate those export sales, subject to VAT Notice 703.

That is the UK side only. It does not remove EU import VAT, or any EU registration that arises if the goods are stored or sold from inside the EU. On the EU side, goods arriving from Great Britain are imports. From 1 July 2021, the European Commission abolished the €22 VAT exemption at importation of small consignments, so all goods imported into the EU are subject to VAT. The Import One-Stop Shop (IOSS) can simplify VAT on distance sales of imported goods in consignments not exceeding €150.

Why the €10,000 OSS threshold does not apply in the same way

Since 1 July 2021, earlier intra-EU distance-selling thresholds have been replaced by a single EU-wide threshold of €10,000, exclusive of VAT, measured across the current and preceding calendar year. The Commission's Guide to the VAT One Stop Shop (revised July 2026) says this threshold applies only where:

the supplier is established or, in the absence of an establishment, has a permanent address or usually resides in only one Member State; and
the supplies are telecommunications, broadcasting and electronic (TBE) services to consumers in another Member State, or goods dispatched from the Member State where the supplier is established to another Member State; and
the total of those supplies does not exceed €10,000, exclusive of VAT, in the current and preceding calendar year.

Only intra-Community distance sales supplied from the Member State where the taxable person is established count towards the threshold. Sales from stock already in another Member State are not included. The threshold also does not apply to distance sales of imported goods — shipments from outside the EU.

A company established only in the United Kingdom is not established in an EU Member State. It cannot treat sales from Great Britain as if they were still under that intra-EU threshold. There is no "first €10,000 of EU consumer sales from the UK, charged at UK VAT" rule after Brexit.

Goods shipped from Great Britain, and goods already in the EU

Treat these as two different flows.

Shipped from Great Britain direct to an EU customer. For UK VAT, these are normally exports. For EU VAT, they are imports. IOSS may be used for consignments not exceeding €150. A non-EU business that wants to use the import scheme must appoint an EU-established intermediary. PanVAT does not act as an IOSS intermediary. Direct exports do not, on their own, create the same local registration duty as holding stock in a customer's country, but EU import VAT still applies. See OSS versus local VAT registration and our OSS registration and returns service.

Stored in an EU warehouse or Amazon fulfilment centre. Sales from that stock to a customer in the same country are domestic sales and need a local VAT return, so you generally need a local VAT registration there. If Amazon holds your stock in several countries, you typically need a number in each one. See Amazon FBA: EU stock means VAT registration. PanVAT can help you register in Germany, France, Spain, Italy, Poland, the Czech Republic, Austria and Ireland. See the VAT registration hub. UK VAT is separate; start with UK VAT registration.

A non-EU business with a local registration in a Member State from which goods are dispatched can then use the Union OSS to declare intra-Community distance sales of those goods to consumers in other Member States. The Member State of identification is where the dispatch begins. If goods leave from more than one Member State, you may choose one of those States and are bound by that choice for the current calendar year and the two following years. Union OSS does not replace the local VAT return for domestic sales from that stock, and it does not cover movements of your own goods between Member States.

Services, fiscal representation and Northern Ireland

If you supply services from the UK to customers in the EU, GOV.UK says you can register for the non-Union VAT OSS, choosing any Member State as the Member State of identification. That scheme is for B2C services. It is not a substitute for goods registrations, and it is not IOSS.

Some EU countries require a non-EU business, including a UK company, to appoint a local fiscal representative when it registers for VAT. Others do not. Official rules for France, Italy, Spain and Germany are in Do you need a fiscal representative for EU VAT?. PanVAT can provide representation where it is required, at €25 per country per month on our pricing page, with Italy priced on request because of a €50,000 VIES guarantee. Official-source examples are France, Italy and Spain; Germany generally does not require one for ordinary taxable sellers. See our fiscal representation service.

Sales of goods from Northern Ireland to EU consumers are not treated as Great Britain exports. If their total value exceeds £8,818, GOV.UK says you must pay VAT in the destination countries and can use the Union OSS or register in each country of supply. See the Northern Ireland OSS guidance.

How PanVAT can help

If you are a UK company selling into the EU, we can map whether you need local registrations, Union OSS, non-Union OSS for services, or a fiscal representative, and then handle the filings. We do not act as an IOSS intermediary. An EORI number may also be needed if you export goods. VAT registration is free with an annual plan. Published EU prices, checked on 12 November 2026, are on our pricing page, including Professional at €79 per country per month billed annually, or €90 monthly, and OSS at €199 registration and €89 filing per country per month. For non-EU clients, prices may differ due to local VAT regulations for non-EU sellers. No UK prices are quoted, because pound sterling amounts have not been set.

Get a free consultation — the first 30 minutes are free. You can also read our VAT consultation page. Call +44 7309 101377.

This article is general information, not tax advice for your situation. Last reviewed: 12 November 2026.