UK VAT for EU Brands Selling Online in 2026

Updated September 2026

EU brands selling online to UK customers must register for UK VAT from their very first sale if they have no UK establishment. The £90,000 registration threshold does not apply to non-established taxable persons (NETPs). In September 2026, the UK standard VAT rate is 20%, and HMRC requires quarterly returns filed through Making Tax Digital (MTD) compatible software.

Most guides on this topic get the direction wrong. They explain how UK brands sell into the EU. This guide covers the opposite: what an EU brand needs to do about UK VAT when selling to UK consumers online, whether through TikTok Shop, Shopify, Amazon, or any other channel.

CRSSBRDR™ is the only MoR built by a licensed accountant and a founding TikTok Shop Partner agency. We get US and EU brands live on TikTok Shop UK in 7 to 10 business days. £100M+ in ecommerce sales driven. Compliance built in, growth switched on.

What are the UK VAT rules for EU brands after Brexit?

Since 1 January 2021, the UK operates a completely separate VAT system from the EU. EU brands are now treated identically to any other overseas seller. The EU's One Stop Shop (OSS) scheme does not cover UK sales (European Commission VAT rules, 2021).

Three rules matter:

1. No registration threshold for overseas sellers. UK domestic businesses get a £90,000 threshold. EU brands classified as NETPs get a £0 threshold. You must register for UK VAT before your first taxable supply in the UK (HMRC VAT Registration Manual VATREG37050, September 2026).

2. The £135 consignment rule applies to goods shipped from outside the UK. For consignments valued at £135 or less, the overseas seller must collect UK VAT (20%) at checkout and remit it to HMRC. For consignments over £135, import VAT and customs duty are collected at the UK border (HMRC Notice 143, September 2026).

3. Storing goods in the UK triggers immediate registration. If you use a UK fulfilment centre, Amazon FBA UK, or Fulfilled by TikTok (FBT), you must register for UK VAT regardless of sales volume (HMRC guidance on overseas goods in UK warehouses, 2026).

Do EU brands get the £90,000 VAT threshold?

No. The £90,000 VAT registration threshold (unchanged since 1 April 2024) applies only to businesses with a UK establishment (HMRC VAT Registration Manual VATREG37050). An EU brand selling directly into the UK without a UK entity is classified as a Non-Established Taxable Person (NETP) under Schedule 1A of the VAT Act 1994.

NETPs must notify HMRC of their liability to register regardless of the value of the taxable supply. The effective date of registration is the date of the first supply or the date the expectation to make taxable supplies first arose.

There is one exception: if you trade through a UK Limited Company (registered at Companies House), that entity is UK-established and benefits from the full £90,000 threshold. This is one reason many EU brands use a Merchant of Record with a UK entity rather than selling directly.

How does the £135 rule work for EU to UK sales?

The £135 consignment threshold determines who collects VAT and where.

Consignments at or below £135 (approximately €155 in September 2026):

• The EU seller registers for UK VAT.

• The seller charges 20% UK VAT at checkout.

• The seller files quarterly UK VAT returns and remits to HMRC.

• No customs duty applies.

• No import VAT is collected at the border.

Consignments above £135:

• Import VAT (20%) and any applicable customs duty are collected at the UK border.

• The courier or freight forwarder typically handles collection from the buyer.

• The EU seller does not collect UK VAT at checkout for these shipments.

• Customs declarations are required.

Online marketplace exception: If sales are facilitated through an online marketplace (Amazon, eBay, TikTok Shop), the marketplace is responsible for collecting and remitting VAT on consignments at or below £135 shipped from outside the UK. The marketplace is also responsible for all sales of goods already stored in the UK, regardless of value, where the seller is overseas (HMRC marketplace guidance, 2026).

What UK VAT obligations does an EU brand have on TikTok Shop?

TikTok Shop UK is classified as an online marketplace under UK VAT law. This means TikTok handles VAT collection and remittance on:

• All consignments at or below £135 shipped from outside the UK.

• All sales of goods stored in the UK where the seller is an overseas business.

However, this does not remove the EU brand's obligation to be VAT-registered in the UK. You still need a UK VAT number to list on TikTok Shop UK. TikTok requires it during seller onboarding.

If you use a Merchant of Record like CRSSBRDR, the MoR's UK entity handles VAT registration, collection, and remittance. The EU brand does not need its own UK VAT number because the MoR is the seller of record for UK VAT purposes.

How do EU brands register for UK VAT?

EU brands register for UK VAT using HMRC's online service. The process takes 4 to 8 weeks in September 2026, sometimes longer for NETP applications (HMRC guidance, 2026).

Requirements:

• A completed VAT1 form (online via Government Gateway).

• Business details: legal name, EU registered address, business activity.

• A UK VAT agent or representative (recommended, not mandatory for most EU countries).

• Bank details for VAT payments (a UK bank account is not required, but simplifies payments).

• Evidence of UK trading activity or intent to trade.

Timeline:

By contrast, an EU brand using CRSSBRDR as its Merchant of Record can be live on TikTok Shop UK in 7 to 10 business days. No separate VAT registration required. The MoR's UK entity is already VAT-registered and acts as the seller of record.

What is Making Tax Digital and does it apply to EU brands?

Making Tax Digital (MTD) for VAT requires all VAT-registered businesses, including NETPs, to keep digital records and file VAT returns using MTD-compatible software. This has been mandatory since April 2022 (HMRC MTD guidance, 2026).

EU brands with a UK VAT registration must:

• Use MTD-compatible accounting software (Xero, QuickBooks, FreeAgent, or similar).

• Keep digital records of all UK sales and purchases.

• File quarterly VAT returns digitally through their software.

• Maintain digital links between records (no manual re-keying of data).

Penalties for non-compliance follow HMRC's points-based penalty regime introduced in January 2023. Each late filing adds a point. Reaching the threshold (4 points for quarterly filers) triggers a £200 penalty.

What are the common UK VAT mistakes EU brands make?

1. Assuming the £90,000 threshold applies. It does not apply to NETPs. You must register from your first UK taxable supply.

2. Relying on EU OSS for UK sales. The EU's One Stop Shop does not cover the UK. UK VAT is a completely separate obligation.

3. Ignoring the marketplace VAT rules. Even though TikTok Shop or Amazon collects VAT, you still need to be VAT-registered and may have filing obligations.

4. Late registration. HMRC can retrospectively register an NETP from the date of the first UK supply and charge penalties and interest on unpaid VAT.

5. Missing the FBT/fulfilment trigger. Storing goods in a UK warehouse triggers immediate VAT registration, even before you make a single sale.

6. Not filing MTD-compatible returns. Paper or spreadsheet-based returns are not accepted. Non-compliance triggers the points-based penalty system.

7. Confusing UK VAT with customs duty. VAT and customs duty are separate obligations. Being VAT-registered does not exempt you from customs declarations or duty payments.

UK VAT compliance checklist for EU brands selling online (2026)

This checklist covers the VAT-specific requirements. EU brands selling physical goods in the UK also need UK product compliance (UKCA marking, UK responsible person, product labelling). See our UK product compliance guide for the full breakdown.

FAQ

Do EU brands need to register for UK VAT in 2026? Yes, if you make taxable supplies in the UK. As an NETP, the registration threshold is £0, not £90,000.

What is the UK VAT rate for online sales? The standard UK VAT rate is 20%. Reduced rates of 5% and 0% apply to specific product categories (children's clothing, books, food).

Does TikTok Shop handle UK VAT for EU sellers? TikTok Shop collects and remits VAT on qualifying sales as an online marketplace. You still need a UK VAT number to register as a seller, unless you use a Merchant of Record.

Can I use my EU VAT number for UK sales? No. UK VAT and EU VAT are completely separate systems since Brexit. You need a UK VAT registration (GB prefix) for UK sales.

How long does UK VAT registration take for EU companies? Typically 6 to 12 weeks for NETP applications, including document preparation and HMRC processing time.

What happens if I sell in the UK without VAT registration? HMRC can retrospectively register you, charge VAT on all past UK sales, and apply penalties and interest.

Is there a faster way to sell on TikTok Shop UK without registering for VAT? Yes. A Merchant of Record like CRSSBRDR handles VAT registration, collection, and filing through its own UK entity. EU brands can be live in 7 to 10 business days.

Do I need a UK bank account to pay UK VAT? No. HMRC accepts payments from non-UK bank accounts, though processing may take longer.

CRSSBRDR™ gets EU brands live on TikTok Shop UK in days, not months. No VAT registration delays. No compliance gaps. Get started.