Brexit: Mixed messages for VAT MOSS users
HMRC guidance on gov.uk indicates that Brexit will immediately affect UK businesses using VAT MOSS from 1 February, in spite of the transitional period which runs until 31 December. However, HMRC press office confirmed on 29 January that this page is out of date.
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So we register for VAT MOSS in Ireland which reports in Euros. UK businesses record their sales in GBP. What rates of exchange do we use? Daily, average, period end?
Would be nice to have some clarity over this. We've already prepared clients for the potential changes and the likely need to register in Ireland, to minimise the language barrier. This just creates more red tape for SMEs than less, but that's been typical of government policy for the last 10 years+
The guidance is out of date and was written for the no deal scenario. However, because the European Parliament has not ratified the Withdrawal Agreement, HMRC is loathe to update the guidance in case something slips up at the EU end and we inadvertently leave with no deal! The EP is due to vote on the Withdrawal Agreement tonight at 18.00 CET, so we should know tonight.
having said all of that, off the record, I have been told that HMRC is expecting the ratification and therefore the transitional period to apply.
Will this impact the info that needs to be provided on the invoice? E.g. additional VAT number?
Love the "clarification" - I quote... " This means EU rules for customs, VAT and excise will continue to apply to the movement of goods". The whole point surely is that MOSS only applies to e-services, not non e-services and certainly not goods. I assume they meant goods and services, because it is a bit late to introduce this if services and e-services are not included in the transition. Incidentally from 1 January 2021 not only will we have left transition (unless it is further extended!!!) but according to the EU the MOSS will become the OSS, One Stop Shop, as the e-services rules will then apply to all supplies of goods AND services within and into the EU. The current distance selling limits for goods (€35,000 or €100,000 depending on the country) will be replaced the current de minimis for e-services of €10,000 if you are a member of an EU state or, of course, NIL if you are not...
What was the outcome from this - was the guidance regarding 31 January 2020 incorrect and we should carry on with our MOSS returns as normal?