Guidance

How to report sales of goods from Northern Ireland to the EU for VAT

Find out how to report supplies of goods from Northern Ireland to VAT-registered customers in an EU country using an EC Sales List.

• From: HM Revenue & Customs
• Published: 18 December 2020
• Last updated: 26 February 2025 — See all updates

Applies to Northern Ireland

If you’re a VAT-registered business in the UK supplying goods from Northern Ireland to VAT-registered customers in the EU, you must tell HMRC.

Find out how to register for VAT to sell or move goods between Northern Ireland and the EU.

You’ll need to use a European Community Sales List (EC Sales List) to show:

• details of each of your EU customers
• the sterling value of the supplies you have made to them
• the customer’s country code

When to complete an EC Sales List

An EC Sales List must be completed if you trade from Northern Ireland and have done any of the following:

• supplied any goods from Northern Ireland to an EU VAT-registered business even if you did not invoice them, unless they count as samples for VAT purposes
• filled in box 8 of your VAT Return
• moved any of your own goods from Northern Ireland to a VAT-registered branch, office or subsidiary company that you own in an EU country
• given an EU VAT-registered customer a credit note for goods supplied from Northern Ireland, even if you did not supply them with any goods in this period
• sold goods to an EU VAT-registered customer and arranged for your EU supplier, to send the goods directly to your customer – this is triangulation

You can zero-rate your supplies of goods from Northern Ireland to EU VAT-registered customers. You must meet the following criteria:

• your customer is VAT registered in an EU member state and has notified you of that VAT number
• the goods are sent or transported out of Northern Ireland to a destination in an EU member state

You must show a valid VAT registration number for your customers on your customers invoice and your EC Sales List.

You’ll also need to include any movements under call-off stock arrangements, such as:

• moved goods to or from the EU
• goods returned to you or now intended for a different customer

Find out how to complete your EC Sales List for call-off stock movement.

When stock is called off (sold) under call-off stock arrangements, and the conditions for this treatment are met, the sale should be reported in the same way as you would report any other sale of goods from Northern Ireland to an EU VAT-registered business. This should be recorded on your VAT return for the period the supply was made.

If you have not supplied goods from Northern Ireland to EU VAT-registered customers or issued any related credit notes, you do not need to complete an EC Sales List unless you have:

• sent call-off stocks from Northern Ireland to the EU
• substituted call-off stocks sent from Northern Ireland to another customer
• had call-off stocks returned to Northern Ireland
• your call-off stocks have not been sold to your customer within 12 months of arrival in the EU
• a relevant event has occurred in relation to your call off stock as listed in ‘moving call-off stock’ section of this guide

When to submit your EC Sales List

When to submit your EC Sales List depends on the value of your supplies.

Monthly EC Sales Lists must be submitted if your total sales in the lasts 4 quarters are over £35,000.

Quarterly EC Sales List must be submitted if your total sales for each quarter in the last 4 quarters is under £35,000.

Annual EC Sales lists can be submitted if you meet the following:

• the value of your total taxable turnover in a year is not more than the VAT registration threshold plus £25,500
• the annual value of your supplies of goods from Northern Ireland to the EU is not more than £11,000
• your sales do not include new means of transport

Deadline for submitting your EC Sales List

You must send your EC Sales list within 21 days of the reporting period. If you miss this deadline, you may have to pay a penalty for any late submissions.

When to use an annual simplified EC Sales List

If you only make low level supplies of goods from Northern Ireland to EU VAT-registered customers, you may be able to send an annual simplified list if:

• the value of your total taxable turnover in a year is less than the VAT registration threshold plus £25,500
• your supplies of goods from Northern Ireland to EU VAT-registered customers is less than £11,000 a year
• your sales do not include new means of transport

The simplified list should:

• include a nominal value of £1 instead of the actual value of your supplies to each customer
• be completed once a year on a date agreed by HMRC

You cannot report movements of call-off stocks using a simplified list.

To check if you can send an annual simplified EC Sales List, contact HMRC VAT enquiries. 

When to send EC Sales Lists as part of a VAT group

You can choose to send individual EC Sales Lists if you have:

• individual branches of your business
• individual companies within a group VAT registration

If you have self-accounting branches within a VAT group, you need to use a 3-digit identifier code in your EC Sales List for each branch or subsidiary. The branches must be Northern Ireland traders.

To send an EC Sales List for individual branches you must register each branch separately using HMRC online services.

Each branch must send a monthly EC Sales List if the total value of goods supplied from all the branches of your business is more than £35,000 (excluding VAT) in the current or previous 4 quarters.

How to complete an EC Sales List

All supplies of goods from Northern Ireland to all EU VAT-registered businesses must be recorded using a line for each customer and for each type of supply. You must include:

• their 2 letter country code
• their VAT registration number
• the total value of supplies to each customer

In the indicator column you must use:

• code ‘0’ for the value of goods and related costs even if you have not invoiced them or been paid yet
• code ‘2’ if you did not handle the goods yourself and your supplier sent them directly to your customer -  this is called triangulation

Moving call-off stock

If you move goods from Northern Ireland to the EU under call-off stock arrangements you must add the following on your EC Sales List:

• the transport of the call-off stocks to the intended customer (the EU VAT-registered businesses)
• any change of intended customer for the call-off stocks
• the return of any call-off stocks to Northern Ireland

You must keep a register with details of call-off stock movements and values.

You’ll need to include the following in your EC Sales List:

• your intended customer’s 2 letter country code
• in the first VAT registration number field add your intended customer’s VAT registration number
• for transport of stock, use code ‘4’ in the indicator column
• the total value of supplies and second VAT registration number fields must be blank

You’ll also need to record any returned call-off stock within 12 months of being in the EU. This includes:

• the period the goods were returned
• record the return of the goods in your register

When you return call-off stock to Northern Ireland without it been called off you must include the following on your EC Sales List for the relevant period:

• your customer’s country code
• your customer’s VAT registration number, in the first VAT registration number field
• the code ‘5’, for returned stock, in the indicator column
• the total value of supplies and second VAT registration number fields must be blank

If there is a change to the intended customer within 12 months of the goods arriving in the EU, you must update your register with the details of the change and include the following on your EC Sales List for that period:

• your original customer’s 2 letter country code
• your original customer’s VAT registration number, in the first VAT registration number field
• your new customer’s VAT registration number, in the second VAT registration number field
• enter the code ‘6’ in the indicator column to indicate the change

For changes to call-off stock to the intended customer do not enter any value of the stock on your EC Sales List.

When call-off stock is called off (sold) the sale must be reported in the same way as you would report any other sale of goods from Northern Ireland to an EU VAT-registered business. This must be recorded on your VAT return for the period the supply was made.

This means that if call-off stocks are moved from Northern Ireland to an intended customer in an EU country and you make a supply of the goods to the intended customer in the same period you must:

• record the movement of the call-off stock in your EC Sales List for the period
• on a separate line, record the sale of goods to that customer

If call-off stocks are not sold within 12 months of arrival in the destination EU country then they must be treated as being supplied to yourself in the destination country and reported as a sale (dispatch) on your EC Sales List.

Read more information on the 12 month rule in section 10.1 of changes to tax rules for call off stock arrangements between the UK and member states.

When certain other events occur to your call-off stock (relevant events), the call-off stocks are treated as being supplied to yourself in an EU country and reported as a sale (dispatch) on your EC Sales List.

Read more information in section 10.2 of changes to tax rules for call off stock arrangements between the UK and member states.

Checking EU VAT numbers

You’ll need to check your customer’s VAT registration number to confirm they are based in the EU. You can:

• contact your customer if they have not given you a VAT registration number or if you do not think the one they have given you is correct – use one of the ready prepared foreign language letters
• ask them for their VAT registration number in your own language
• check that the VAT registration number that your customer has given you is in the right format for that country
• use the VIES on the web service to check if the VAT registration number, name and address is valid – you can also get a certificate of proof of checking

You’ll need to do this for new customers.

Once you have confirmed the VAT registration number is valid, you must include this on your EC Sales List. You should enter your customer’s 2 letter country code and the VAT registration number separately. Do not include:

• spaces, dashes, commas or slashes
• the 2 letter country code as part of the VAT registration number

How to calculate the total supplies to a customer

1. Add up the value of all the supplies of goods you have made in the period, round down to the nearest whole pound.
2. Enter a separate line for each customer and type of supply made. You will need to add separate lines for values of goods supplied and triangular goods supplied.

Enter the values of goods supplied from Northern Ireland to each customer, including:

• costs such as delivery charges and if you charged these or not, minus any credit notes issued
• goods that are moved from Northern Ireland to your own VAT-registered branch, office or subsidiary company in the EU
• any triangular supplies of goods on a separate line using code ‘2’ in the indicator box
• credit notes issued without making any supplies using a minus sign before the amount

Do not include the value of any goods that:

• have been sent for processing
• qualify as samples under the VAT rules

If HMRC has confirmed you can complete an annual simplified EC Sales List because you have low level sales of goods to EU customers then you do not need to include the value of the sales you make. You should enter £1 in the value column.

Submit your EC Sales List online

There are 2 ways you can submit your list online. You can use:

• online form
• bulk upload a file in either Comma Separated Values (CSV) or Extensible Markup Language (XML) format

You can use the online form to submit your EC Sales List if it includes cross-border movements of goods or changes of intended customers under the call-off stock arrangements.

Read information on how to submit EC Sales List using CSV.

You’ll need the Government Gateway user ID and password you used when you registered for VAT.

If you’re exempt and unable to submit your EC Sales List online, contact HMRC VAT enquiries.

Other ways to submit your EC Sales List

You can request a paper EC Sales List if you’re unable to use the online form or bulk upload because:

• you do not use computers for religious reasons
• you do not have access to the internet
• of personal circumstances such as age, health condition, disability or where you live

There may be other reasons you cannot complete your EC Sales List online. HMRC will consider your request.

To submit a paper EC Sales List, you’ll need to contact or write to HMRC and include the following:

• your VAT registration number
• your business name and address
• the reason you’re unable to complete your EC Sales List online
• if you’re applying on someone’s behalf, authorisation from the business

To request a paper form contact HMRC.

After you’ve submitted

After you’ve submitted your EC Sales List, you’ll receive a unique submission reference number. Keep this number for your records.

Updating your EC Sales List submission

To correct any errors on your EC Sales List including call-off stock changes, you must do this within 21 days of your original submission date.

If you are correcting a CSV or XML file, you must upload a new file.

Published 18 December 2020

Last updated 26 February 2025 + show all updates

1. 26 February 2025

   Information on how to complete an EC Sales list online has been updated and how to request a paper EC Sales list has been added.

2. 18 December 2020

   First published.