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Amazon Sales on MTD - 3rd Party Agent Concession?

Does Amazon fall under the Third Party Agent rules for the purpose of Making Tax Digital

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Hi Folks, 

11 days to go until MTD... Something we've discussed to a great extent in the office is whether the following force of law applies to Amazon Sales. 

"Where a third party agent makes supplies on your behalf, those supplies do not fall within the digital record keeping requirements until you receive the information from the agent. Where the information is received as a summary document you can treat this document as one invoice issued by you for the purpose of creating your digital record."

I'd be really interested to hear your opinion's on this matter. 


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By mg200
25th Mar 2019 16:45

You make one entry (sales invoice) to summarise the fortnights Amazon sales. We separate out product sales, Amazon fees etc on the invoice so that we get the VAT treatment correct.

We've done it this way for years and it seems to be compliant with MTD as far as I am concerned.

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Replying to mg200:
By GoldLeader
25th Mar 2019 17:14

Thanks mg200,

Yeah, we do the same currently - we’ve been doing the same for payments through stripe/Shopify etc, but we’re fairly certain data for this falls under the requirement to hold _at least_ daily totals in your bookkeeping software as part of MTD.

I assume you’re considering continuing this way with Amazon as compliant because of the 3rd Party agent rules contained within VAT notice 700/22?

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By mg200
25th Mar 2019 17:56

Yes. My first thought was in the interests of getting an accurate VAT return - which luckily is the same ambition of HMRC for MTD.

Automating each transaction into bookkeeping software in my opinion makes the likelihood of errors slightly more likely in the case of Amazon and others. We do this with Brightpearl clients for instance and need more controls to reduce error.

When I read the VAT notice I was happy that we were not forced to record daily transaction summaries either as it states that 'where the information is received as a summary document you can treat as one invoice'. So no mention of daily.

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