A business is selling goods overseas now wants to incorporate the UK and sell goods from the UK Company to UK Customers. They will not have any physical presence in the UK so no business or fixed establishment under
The reason for a UK company is just really to show to UK Customers they are selling from UK. The UK company would pay the import VAT. The goods would probably be shipped straight to the UK Customer from overseas.
They prefer to sell from the UK company but have to showing they are making taxable supplies in the UK. The UK company will enter into a contract with the UK customers and issue invoices which I know HMRC will want to see evidence of before issuing the VAT Registraton.
I understand the UK company can be a Non Established Taxable Person even though the UK company is being managed from overseas hence there is no VAT threshold.
What I am trying to distinguish who is making the taxable supplies i.e UK or overseas company - perhaps case of form over substance ? Can HMRC say that the overseas company is actually making taxable supplies and disallow any claim for any input/import VAT.