The Finance Blog
The Finance Blog
Ever tried making sense of VAT when you’re offering services across borders? It’s like opening a map with no compass — especially if you’re a freelancer, small business owner, or digital service provider working with clients in the EU or beyond.
Understanding cross-border VAT isn’t just about ticking boxes for HMRC — it’s about staying compliant, keeping your costs transparent, and making sure you’re charging the right amount at the right time. With shifting regulations, post-Brexit changes, and digital services flying across time zones, VAT rules have become more complex — but not impossible to master.
In this guide, you’ll learn:
Let’s break it down, step by step — in plain English, without the jargon overload.
Value-Added Tax (VAT) is a consumption tax applied at each stage of a supply chain — from production to final sale. In your home country, the rules are relatively straightforward. But once you start crossing borders, especially outside the UK, everything changes.
Why? Because:
Let’s say you’re a graphic designer in London working for a client in Berlin. Should you charge VAT? Should they pay it? Do you need to register in Germany? These are the kinds of questions that baffle even seasoned professionals.
To keep things clear, here are a few essential terms:
Understanding how these definitions apply is key to compliance.
When you sell services to a VAT-registered business in another country, the Reverse Charge Mechanism usually applies.
This means:
Example: You’re a UK-based SEO consultant billing a VAT-registered business in France. You issue an invoice with no VAT, stating “Reverse charge applies”.
Why is this great? Less admin for you, and the buyer handles VAT on their end.
Important: The invoice should always include the customer’s VAT number and a note like “Subject to reverse charge.”
This is where it gets tricky.
When selling to non-business customers (i.e., individuals), you often must charge VAT based on the customer’s location, not yours.
Digital services (e.g. streaming, e-books, software, online coaching) are a key example:
Post-Brexit Alert: UK sellers can no longer use the EU OSS scheme. You might need to appoint an EU fiscal representative and register for VAT in an EU country.
Not all services are treated the same. Here’s a snapshot of how VAT applies across categories:
Top Tip: The EU VAT Rules Explained website is a lifesaver for category-specific rules.
You’re required to register for VAT in the UK if:
But even if you’re under the threshold, you may need to:
Since Brexit, UK businesses must register in one EU country and use the Non-Union One Stop Shop (OSS) to declare VAT across all EU sales. It simplifies things.
But you still need to:
Let’s look at a common case:
Emma, a UK-based freelance writer, sells:
Here’s how VAT applies:
Emma uses a platform that handles VAT for her, but had she sold directly, she’d have to handle foreign VAT herself.
Moral of the story? Understand your setup, and use platforms wisely if you’re not ready for complex registrations.
If you’re based within the EU, the rules are slightly different:
For non-digital services (e.g., consultancy), check the local place-of-supply rules — not all services follow the same logic.
Don’t overlook your invoices. They must be:
Here’s a quick checklist:
Requirement | B2B Sale (EU) | B2C Sale (EU) |
---|---|---|
Charge VAT? | No | Yes (local rate) |
Show customer VAT number? | Yes | No |
Add “Reverse charge” note? | Yes | No |
Register in the customer’s country? | No (via OSS optional) | Yes (via OSS needed) |
Navigating cross-border VAT might feel like learning a new language, but once you grasp the basics of B2B vs B2C, the importance of location, and how VAT registration fits into the picture, it becomes far more manageable.
Whether you’re freelancing, running a digital store, or launching an app, understanding your EU services obligations ensures you’re not caught off-guard — or out of pocket. You’ll not only protect your business legally but also come across as more professional to your international clients.
Now it’s your turn: