The export of goods from the ROI, or within the EU, to territories outside the EU (ie. UK), must be declared at the Irish/EU point of exit prior to export. In this regard, you need to hold an Irish EORI number in order to declare same.
Where Irish VAT registered traders export to outside the EU, the zero rate of VAT applies. However you are required to hold evidence of export of goods for VAT purposes.
Similar to the importation of goods from the UK to ROI, UK customs duty and VAT obligations arise where goods are imported from the EU into the UK. In order for the goods to clear Customs, one of the following needs to occur:
You will be required to declare and discharge any UK custom duty that may arise on the imported goods, but are not required to have a UK Company or have a “Permanent Establishment” for UK Corporation Tax purposes.
You will need to consider whether you will submit import declarations direct or through a third party customs broker, freight forwarder or logistics provider, as many UK and Irish ports operate a roll-on roll-off basis so that goods may have to be declared and customs duty discharged prior to boarding ferries.
The HMRC have announced a deferral on the payment of UK Import VAT however the conditions of same have yet to be finalised.
In the event of a no-deal/hard Brexit and the UK leave the EU common market, your business will be impacted by additional Customs and VAT requirements.
Where you export goods to the UK, your business will need to consider the implications of acting as both the Irish exporter and UK importer with regard to UK Customs Duty and VAT. You will have to consider your business’s profitability, cash flow and supply chain requirements in order to determine if the benefits of passing these additional costs on to your UK customer outweighs the cost of you incurring same.
Return to the Tax Issue - March 2019
