On 1 January 2021, the UK left the EU VAT regime. Although the UK has retained a VAT system, it now operates on the basis that it is a third country (with the exception of goods supplied to and from Northern Ireland (“NI”), which continue to be treated as intra-EU trade for VAT purposes).

The UK Government’s agreement of the Trade and Co-operation Agreement with the EU does not change the VAT position. The TCA contains minimal provisions relating to VAT and with the exception of NI trade in goods, the UK is in most respects expected to be treated as any other third country for VAT purposes.