Do non-UK companies need to register for UK VAT?
Yes, if they make taxable supplies in the UK and have no UK establishment. The £90,000 threshold that UK businesses use does not apply to them. A single taxable sale is enough to create the obligation.
Common UK taxable supplies by overseas businesses include:
- selling goods that are already in the UK, such as stock in a UK warehouse or Amazon FBA
- selling software, apps, streaming or other digital services to UK consumers
- importing goods and selling them on to UK customers
- some services where the UK is the place of supply, such as work on UK land or admission to UK events
Registration timeline for an overseas business
- Day 0Your first UK taxable sale, or the day you first expect one within 30 days. This is your registration date.
- By day 30Apply to HMRC online, or through an agent.
- Up to 40 working daysHMRC issues your VAT number. Allow longer if it asks questions.
- Within 30 days of the numberSend VAT invoices for sales made since day 0.
Is there a VAT threshold for overseas businesses?
No. A non-established taxable person must register for UK taxable supplies of any value, including digital services. The threshold only applies to businesses established in the UK.
| UK-established business | Overseas business (NETP) | |
|---|---|---|
| Registration threshold | £90,000 in any rolling 12 months | £0 |
| Deadline | 30 days from the end of the month you go over | 30 days from the first UK taxable supply |
| Registration address | UK business address | Principal place of business outside the UK |
| Tax representative | Not applicable | Only if HMRC directs |
| Making Tax Digital | Yes | Yes |
What is a NETP (non-established taxable person)?
A NETP is any business or individual that makes taxable supplies in the UK without a UK establishment. HMRC uses the term in VAT Notice 700/1. A company incorporated abroad with no UK office, staff or management is the typical example.
You are UK-established if your essential management decisions and central administration happen in the UK, or you have a permanent UK presence with the people and equipment to make or receive supplies. A registered, serviced or virtual office alone does not make you established. Our guide to what counts as a UK establishment covers the two tests in detail.
When does an overseas business not need to register?
An overseas business may not need to register if every UK sale falls into one of three groups:
- All zero-rated. Every UK supply is taxable at 0%.
- All sold through an online marketplace to consumers. The marketplace accounts for the VAT on those sales. See rules for marketplace sellers.
- All to UK VAT-registered businesses who apply the reverse charge. The customer accounts for the VAT instead of you.
If any sale falls outside these groups, you must register. For the first two groups, you apply to HMRC for exemption rather than simply not registering. Registering anyway can make sense if you pay UK import VAT on stock and want to reclaim it.
Can I register for VAT without a UK address?
Yes. HMRC registers a NETP at its principal place of business, which is where orders are received and the business is run day to day. It must be outside the UK. A third-party address, such as a mail-forwarding, registered office or UK fulfilment centre address, is not accepted.
How to get a UK VAT number as a foreign company
- Confirm you have no UK establishment. If you do, the £90,000 threshold applies instead and the steps differ.
- Fix your registration date. It is the date of your first UK taxable supply, or the date you first expected to make one within 30 days.
- Gather your documents. Your certificate of incorporation, directors’ details, overseas business address, a description of what you sell to UK customers, and evidence such as contracts, marketplace account details or invoices. The how-to guide has the full checklist.
- Apply online. Use HMRC’s online VAT registration service, or have an agent apply for you through HMRC’s agent services. You will need an estimate of taxable turnover for the next 12 months.
- Answer HMRC’s questions. HMRC often asks overseas applicants for more detail about who runs the business, where, and what it sells in the UK.
- Receive your VAT number. You get a VAT registration certificate. From then on you charge UK VAT, keep digital records and file returns under Making Tax Digital.
While you wait for your number
You can charge VAT from your registration date. Until your number arrives, show prices as VAT-inclusive, don’t show VAT as a separate amount, and note on the invoice that a VAT number has been applied for. Once your number arrives, send proper VAT invoices for those sales within 30 days, so VAT-registered customers can reclaim the VAT. See how long registration takes.
Do I need a UK tax representative?
Usually not. HMRC can direct a NETP to appoint a UK tax representative or to provide security, but it cannot direct businesses based in countries that have a mutual assistance arrangement with the UK. A tax representative is jointly and severally liable for your VAT debts; an agent is not. Compare the two in tax representative or agent.
Common scenarios
“We’re a US SaaS company with UK customers. Do we need to register for UK VAT?”
If any of your UK customers are consumers, yes, from the first sale. Digital services to UK consumers are taxed where the consumer is, and a US company with no UK establishment has no threshold. If every UK customer is a VAT-registered business, the customer usually accounts for the VAT under the reverse charge and you often don’t need to register. See UK VAT on SaaS.
“We’re an EU retailer holding stock in a UK warehouse.”
Selling goods already located in the UK is a UK taxable supply, so you must register within 30 days of the first sale, unless you sell only to consumers through an online marketplace. You normally pay import VAT when stock enters Great Britain. Registering lets you reclaim it, often through postponed VAT accounting. See selling goods into the UK.
“We sell on Amazon UK from China using FBA. What are our VAT obligations?”
If you sell only to consumers through Amazon, Amazon accounts for the VAT on those sales and you can apply for exemption from registration. You must register if you also sell off-marketplace, if Amazon passes on a business customer’s VAT number, or if you want to reclaim import VAT on your stock. Marketplaces can remove sellers who should be registered but aren’t.
“I’m a consultant outside the UK billing UK businesses.”
For most business-to-business services, the UK customer accounts for the VAT under the reverse charge, so you usually don’t need to register. Exceptions include services connected with UK land and admission to UK events. Check each contract before assuming.
“Can a Dubai company register for UK VAT without a UK office?”
Yes. It registers as a NETP using its principal place of business in the UAE. It doesn’t need a UK office, and renting a UK virtual office would not change its status. HMRC can direct NETPs from countries without mutual assistance arrangements with the UK to appoint a tax representative or pay a security, so we check this before every application.
“I only sell to UK businesses. Do I still need a UK VAT number?”
Often no, if every customer is VAT-registered and accounts for the VAT under the reverse charge. If you sell goods that are held in the UK, even to businesses, you normally still need to register. Keep evidence of each customer’s VAT number and business status.
From our casework (as at 27 September 2026)
Where the directors are overseas and have never been involved with a UK VAT-registered business, HMRC typically takes the full 40 working days to issue a VAT number. UK directors with a history in a VAT-registered UK business usually see a number in 4 to 6 weeks. See how long registration takes.
What if I should have registered already?
Register now. If you don’t, HMRC can register you without your agreement. Either way, it registers you from the date you should have been registered, and you owe VAT on UK sales from that date even if you didn’t charge it. A late-registration penalty can be up to 30% of the VAT due if the failure wasn’t deliberate, or as little as 0% if you tell HMRC before it finds out. See late registration penalties.
Would a UK company be better than registering from abroad?
Sometimes. If you plan to hire in the UK, hold UK contracts or need a UK bank relationship, a UK subsidiary may make sense. A UK-incorporated company that can make and receive supplies at its UK address is normally UK-established, and then uses the £90,000 threshold instead. Our sister site UK Establishment covers company formation for overseas founders.
Selling into the UK? We’ll register you.
We register overseas businesses with HMRC as their agent, answer HMRC’s questions, and file your returns once you’re live. Already late? We can file your registration and a disclosure.
Frequently asked questions
What is the deadline for NETP VAT registration?
You must register within 30 days of your first UK taxable supply, or within 30 days of the date you first expect to make one in the next 30 days. HMRC registers you from that date even if you apply late.
Can I register for UK VAT before my first sale?
Yes, once you expect to make a UK taxable sale within the next 30 days. From that point you are required to register, and you must tell HMRC within 30 days of the date that expectation arose. Applying early helps your VAT number arrive before you start selling.
Do I also need an EORI number?
Usually, if you move goods into or out of Great Britain. You need an EORI number starting with GB, because an EU EORI number is not accepted for GB customs. It is a separate registration from VAT. See selling goods into the UK.
Do overseas businesses have to file VAT returns under Making Tax Digital?
Yes. Making Tax Digital applies to every VAT-registered business, including NETPs. You keep digital records and file returns, usually quarterly, through compatible software.
Can HMRC refuse an overseas VAT application?
HMRC can ask for more information or refuse an application if it isn’t satisfied the business is genuine or will make UK taxable supplies. Clear evidence of trading, such as contracts or marketplace accounts, reduces the chance of delays.
Related guides
Sources
- HMRC VAT Notice 700/1: Who should register for VAT — non-established taxable persons, UK establishment, online marketplaces, late registration. Updated 5 August 2026
- HMRC VAT Notice 741A: Place of supply of services
- GOV.UK: Register for VAT
General information based on HMRC guidance as at 27 September 2026, not advice for your situation. Rules change and depend on your facts. Talk to us before acting.