VATREVCHG31000 - The Reverse Charge Sales List (RCSL): The legal obligation to submit an RCSL

Introduction

From 1 July 2022, businesses are no longer required to report information to HMRC about sales of mobile phones or computer chips in the UK. This does not remove the requirement for businesses to operate the reverse charge procedure.

However, businesses are still required to report such sales up to and including 30 June 2022 and the following guidance still applies.

From 17 October 2022, businesses are no longer able to submit a sales list or make any amendments via the online portal.

The following guidance is historical and only applies to sales of mobile phones or computer chips up to and including 30 June 2022.

Any VAT registered taxable person who supplies goods specified in the Value Added Tax (Section 55A)(Specified goods and services and excepted supplies) Order 2010 must submit an RCSL. Failure to submit an RCSL may incur a penalty.

RCSLs do not include the supply of a specified service.

The legal provisions

The law relating to a taxable person’s legal obligation to submit a RCSL is set out in Part IV, Regulations 23A-23D of the VAT Regulations 1995 (SI 1995/2518).

When a taxable person makes a supply of specified goods, he must notify the Commissioners of that fact within 30 days of the day on which the supply is made. This notification and submission must be done online or, in exceptional circumstances, where HMRC may decide that this can be done by email, and includes nil returns.

Failure to submit an RCSL

If a taxable person fails to submit an RCSL he may be liable to a penalty. VATREVCHG32000 looks at this issue in more detail.