Potential relaxation of time limits for VAT free exports

Julian Borley
Director of VAT | Milsted Langdon LLP
8th June 2020

There have been a number of high-profile business reliefs which have been introduced to alleviate the impact of the COVID-19 pandemic.

However, one potential relaxation has been set out in HMRC’s internal manuals without a great deal of publicity or fanfare.

Normally when goods are sold from the UK and exported to a destination outside the EU there are a number of conditions which must be met, for example strict deadlines stating the goods must be exported or removed within specified time limits.  Generally, the time limit for removing the goods from the EU and obtaining evidence of export is 3 months from the date of supply of the goods.

HMRC’s Internal Manual ‘VAT Export and Removal of Goods From the EU’ highlights some of these conditions. However, HMRC have amended the VEXP30310 page of this document to suggest that tax-payers can now get HMRC’s agreement that the time limit for export can be extended.

This relaxation is very much at HMRC’s discretion and they envisage it applying if the transportation is delayed because of restrictions to travel or the individuals handling the transportation are incapacitated due to illness. HMRC also expect that the goods in question will still be exported or removed at the “earliest opportunity”.

The larger exporters may have a dedicated VAT officer assigned to their businesses and it is suspected that they may find it easier to negotiate the relaxation than those businesses which will have to apply through the VAT Enquiries Team (who themselves may not have been made aware of the changes to the Manual).

If your business has any questions in respect of the rules regarding the VAT treatment of exports (particularly if your business is unaware of the required conditions for evidence and time limits for ‘Zero Rating’ exports, then please contact our dedicated VAT specialists on vat@milstedlangdon.co.uk

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