Trading with the UK after Brexit – VAT, customs duties, and strategy
Following Brexit, the UK is a third country, and trading with the UK now requires managing both VAT and customs duties. It has become more bureaucratic—but is entirely manageable with the right setup. Here is an overview of your options for B2C, B2B, and marketplaces, as well as how to avoid the costliest pitfalls.
What does Brexit mean for your trade with the UK?
In short: The UK is a third country, so customs and VAT must be handled in trade. The free trade agreement between the EU and the UK provides for duty-free trade – but kun for varer med oprindelse i EU eller UK. Sælger du varer med oprindelse i fx Kina videre til UK, kan der pålægges told uanset aftalen. Til korrekt udførsel kræves et EORI-nummer og dokumentation for varens oprindelse.
That changed with Brexit.
- Customs duties and rules of origin: Duty-free status requires the goods to originate in the EU or the UK, and for this to be documented.
- VAT liability for B2C: UK VAT liability has been introduced for parts of B2C online sales to UK consumers.
- Marketplaces (OMP): Trade via digital platforms such as Amazon has its own VAT and delivery requirements.
- EORI and documentation: Proper execution requires an EORI number and proof of origin.
Strategic considerations for your business
Before formulating your UK strategy, there are three questions worth considering:
Are you going to give up on the sale?
If the costs and hassle are excessive relative to the level of activity, and you would prefer to prioritize other markets. This applies particularly to B2C, but also to B2B and OMP.
Can you negotiate new terms?
Danish companies can no longer deliver on a DDP basis to a British B2B customer’s address without being VAT-registered. Will the customer handle import VAT and customs duties themselves—or demand a price reduction?
Do you need to act proactively?
The VAT registration required for B2C sales can also be leveraged to offer DDP delivery to B2B customers as a service. Selling via Amazon requires DDP—and therefore VAT registration.
Moving forward – key UK topics
Dive into what is relevant to your business:
- VAT in the UK: rates, the £135 threshold, VAT registration, and when you are liable for VAT.
- Customs and customs clearance after Brexit: rules of origin, EORI, and customs clearance requirements.
- Amazon & Marketplaces (OMP): VAT and delivery requirements for sales via platforms.
- VAT Refund: recover the VAT you paid on UK expenses.
How TIMEVAT helps you with the UK
TIMEVAT is a Danish firm specializing in finance and exports, with its own office in Manchester and particular expertise regarding the UK. We have closely monitored the regulations since Brexit and assist you every step of the way: VAT registration, løbende reporting, EORI, fortoldning og oprindelsesdokumentation. Vi bliver din forlængede arm til de britiske myndigheder og passer på din forretning, som var det vores egen.
Shall we help you get started in the UK?
Give us a call, and we’ll have a no-obligation chat about your situation and your options.
Contact us – call +45 7021 3000Frequently asked questions about Brexit and the UK
Is there still customs duty on goods to the UK?
The free trade agreement provides for duty-free treatment of goods originating in the EU or the UK. Goods originating in a third country (e.g., China) that are forwarded to the UK may be subject to customs duties, regardless of the agreement.
What is a rule of origin?
This is the requirement that a good must originate in the EU or the UK to qualify for duty-free status. You must be able to document the origin in order to use the free trade agreement.
Do I need to register for VAT in the UK?
Often yes – especially for B2C sales and trading via marketplaces. See the details on the page about moms i UK, eller kontakt os for en konkret vurdering.
What is an EORI number?
A number that identifies your business for customs clearance purposes. You apply for it through the Danish Business Authority, and it must be provided for exports to the UK.
Can I still deliver DDP to my UK customers?
Yes, but in principle, this requires a UK VAT registration. In return, you can offer DDP as a service and track the delivery all the way to the customer's door – including for B2B and Amazon orders.
