UK businesses who sell digital or broadcasting services to non-business customers in the EU will be used to completing an EU VAT MOSS return by 20th of the month following the end of the calendar quarter. Those with small volumes of cross-border digital sales could avoid VAT MOSS returns altogether if their annual sales fell under the de-minimis threshold of £8,818.

Now that the UK is no longer treated as a member of the EU, as the Brexit transition period has ended, UK businesses are not eligible to use the EU VAT MOSS system. Those UK businesses who continue to sell digital services to non-businesses customers in the EU must use the non-EU VAT MOSS scheme, for which there is no de-minimis sales threshold.

To register for non-EU VAT MOSS the trader must first have an EU VAT number, and UK VAT numbers don’t qualify. The trader must register for VAT in an EU country, and this may require appointing a local tax agent.

The UK trader should register for non-EU VAT MOSS by 10th of the month following the month in which the first digital services sale is made to a non-business customer within the EU. If such a sale is made in January 2021 the UK trader needs to register for non-EU VAT MOSS by 10 February 2021.

The alternative to registering for non-EU VAT MOSS in one EU country, is to register for VAT in each EU country where the business supplies broadcasting or digital services.