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Is this triangulation?


Question about 'Outside the scope of UK VAT'.

Movement of goods is from NL to Germany.

UK supplier invoices our company (in the UK) without VAT for those goods (from their warehouse in NL).

We invoice our Customer in Germany without VAT 'sales to EC customers' (record on ECSL).

I'm told by HMRC that the transaction is 'outside the scope of UK VAT.

So would both Supplier invoice and Customer invoice be recorded as T9 in Sage?

Liz Shirley


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05th Oct 2007 15:44

I think so!
As the place of supply is outside the UK then it is no concern to the UK Vatman. T9 seems appropriate.

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05th Oct 2007 16:35

Yes - it is triangulation
If you are not registered for VAT in Germany, you must be using the simplified procedure. The conditions include:

- It is your UK VAT number which permits your NL supplier to zero-rate their invoices to you
- In addition to using your German customer's VAT code on your sales invoice, you must quote "VAT: EC Article 28 Simplification invoice"
- On your ECSL, you must state the total of your triangular supplies to your German customer on a separate line from any direct supplies, with "2" in the indicator box
- You should omit all details of incoming and outgoing triangular transactions from your VAT and Intrastat returns. If that is the consequence of using T9 in Sage, go for it.

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08th Oct 2007 11:25

Possibly not triangulation
Does your "UK" supplier own the goods and have a VAT registration in NL? If so, then it is triangulation because there are 3 parties.

If the UK supplier is sourcing the goods from a NL supplier and does not have a NL VAT registration then it is not triangulation because there are 4 parties. In this event, either your supplier should be required to register for VAT in NL or you may be required to register for VAT in Germany depending upon where the supply of the goods is deemed to occur.


Paul Taylor
Senior VAT Consultant

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09th Oct 2007 11:52

Thanks for the replies so far.

We aren't registered for VAT in Germany and will put the Article 28 statement on our invoices.

Our invoice will not show a VAT amount, the Customers DE VAT number will appear on the invoice.

The supplier is invoicing us from the UK, their warehouse is in NL. The supplier invoice also states the DE VAT number of our customer.

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