By Touseef Aslam FCCA, Founder & Director, PanVAT | UK VAT & Indirect Tax ConsultantPublished 2026-11-06
About 6 minutes to read · Rules checked against GOV.UK and HMRC guidance on 4 November 2026
If your business is based outside the UK and you sell goods or services in the UK, you may need UK VAT registration from your very first sale. This guide to UK VAT registration for overseas companies explains who counts as a non-established taxable person (NETP), why the usual £90,000 threshold does not apply to you, how to register, and what happens afterwards.
What is a non-established taxable person (NETP)?
HMRC defines a NETP as any person who does not have a UK establishment. In VAT Notice 700/1, a UK establishment exists if either:
- the place where essential management decisions are made and central administration is carried out is in the UK, or
- the business has a permanent physical presence in the UK with the human and technical resources to make or receive taxable supplies.
A registered, serviced or virtual office alone is not enough to create a UK establishment. So an overseas company with only a UK mailing address, or stock in a UK fulfilment centre, is normally still a NETP.
No threshold: NETP VAT registration starts with your first UK sale
UK businesses only have to register once taxable turnover goes over £90,000 in a rolling 12 months, or is expected to within 30 days. That threshold does not apply to NETPs.
According to GOV.UK, you must register regardless of turnover if all of these are true:
- you're based outside the UK
- your business is based outside the UK
- you supply any goods or services to the UK, or expect to in the next 30 days.
VAT Notice 700/1 says a NETP must register if it makes taxable sales in the UK or expects to in the next 30 days, and must tell HMRC within 30 days of becoming liable. A taxable sale is any UK transaction that is not exempt from VAT. In short, non resident VAT registration in the UK is triggered by the first taxable supply, whatever its value.
When an overseas company may not need to register
VAT Notice 700/1 lists situations where a NETP may not need to be registered:
- all your sales to the UK are zero-rated
- you're an overseas seller and all your UK sales go through an online marketplace to non-business customers
- you're an EU-based business selling goods to non-taxable customers in Northern Ireland (distance selling rules apply)
- all your UK sales are to VAT-registered businesses in Great Britain that account for VAT under the reverse charge.
If all your sales to the UK are exempt from VAT, you cannot register. Where you rely on zero-rating, you can apply for exemption from registration online through HMRC's VAT registration service, or by post using form VAT1.
Selling through Amazon and other online marketplaces
Online marketplace rules matter for many overseas sellers:
- Goods in the UK at the point of sale: if you're an overseas seller and your goods are already in the UK when sold (for example in a fulfilment centre), you must register, charge and account for VAT, whatever their value. Where the sale is to a consumer through a marketplace, the marketplace is treated as the supplier and your supply to it is zero-rated, so you can ask HMRC for exemption from registration.
- Goods outside the UK, consignments of £135 or less: when sold to consumers through a marketplace, the marketplace accounts for the VAT. HMRC's manual says these sales are not taxable supplies for your registration purposes, provided the goods contain nothing subject to excise duty.
- Selling direct (not via a marketplace): consignments of £135 or less imported into Great Britain are treated as supplied in the UK, so you charge UK VAT at the point of sale and must register.
You will still need to register if, for example, the marketplace gives you a business customer's VAT details, or you make a UK taxable sale outside a marketplace. For a deeper look at seller scenarios, read our guide to UK VAT for overseas online sellers.
How to register for UK VAT as an overseas company: step by step
- Confirm you're a NETP. Check where management and day-to-day running of the business happen, as above.
- Work out your registration date. This is when you first made, or expect within 30 days to make, a UK taxable supply. Apply within 30 days.
- Gather your details. HMRC's VAT1 notes ask non-UK businesses for the equivalent company or tax reference from their home country, plus contact details.
- Register online. Use HMRC's online VAT registration service. You'll be registered at your principal place of business, which must be outside the UK and should not be a mail-forwarding or registered office address.
- Decide on representation. Say whether you're appointing a UK tax representative (form VAT1TR) or an agent (see below).
- Wait for HMRC. HMRC sends your VAT number, when to submit your first return and payment, and your effective date of registration by post.
- Set up your VAT online account as soon as you receive your VAT number.
If you use an agent, GOV.UK is clear that you must not give them access to your own online account. Agents use their own authorised access instead.
Do you need a UK VAT representative?
In most cases, no – it's optional. VAT Notice 700/1 says you can appoint a UK VAT representative or a VAT agent, or deal with HMRC yourself. If you choose neither, you're responsible for accounting for UK VAT to HMRC.
The difference matters:
- Tax representative: keeps your VAT records, accounts for UK VAT on your behalf and is jointly and severally liable for your VAT debts. You appoint one using form VAT1TR.
- VAT agent: handles registration and returns for you but does not take on your VAT liability.
HMRC can direct some NETPs to appoint a UK-based, "fit and proper" tax representative, or ask for a security. It cannot direct NETPs based in countries with certain mutual assistance arrangements with the UK.
After registration: Making Tax Digital and ongoing duties
Once registered, HMRC signs your business up to Making Tax Digital (MTD) for VAT unless you're exempt or have applied for an exemption. That means keeping digital records and filing VAT returns through MTD-compatible software.
You must also charge VAT at the correct rate on UK sales, pay HMRC the VAT you owe from your registration date, and declare your total sales, including zero-rated sales, on each return. Our UK VAT returns service covers this part.
What if you registered late?
If you register late, you must pay VAT on any sales made since the date you should have registered. GOV.UK says you might also have to pay a penalty, depending on how much you owe and how late your registration is. Because there is no threshold for NETPs, it's easy to become liable earlier than you think, so check your position before your first UK sale.
Get your UK VAT registration right first time
PanVAT has helped businesses with VAT registration and returns in the UK and across Europe since 2019. We can confirm whether you're a NETP, prepare and submit your UK VAT registration, and set you up for MTD filing.
Book your free consultation – the first 30 minutes are free, and we'll tell you exactly when and how you need to register.