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The National Export System (NES), which will be replaced by the Customs Declaration Service (CDS) at the end of March 2024, doesn’t require an exporter to declare whether or not they are zero-rating their export for VAT purposes. Exporters can claim VAT zero rating against official and/or commercial transport evidence of export.
The same evidence of export is required with the Customs Declaration Service. However, in addition, an exporter wishing to VAT zero rate at export must complete Data Element 6/17 with National Additional Code VATZ. Failure to do so may lead to HMRC disallowing VAT zero-rating of the export at subsequent audit.
However, it is also important to understand when VATZ is not required on an export Customs declaration through the CDS.
In particular, if VATZ is input on a temporary export, VAT relief cannot be claimed at re-importation.
VAT Notice 703 states that an exporter need not account for VAT where there is no taxable supply. It further states that an exporter need not account for VAT if they:
- supply and export goods which they are to install outside the UK for their customer (the supply takes place in the country where the goods are installed).
- export goods temporarily for exhibition or processing.
- export goods on sale or return, where the goods remain the exporter’s property until they are sold.
However, exporters must still hold valid proof of export (read sections 6 and 7 of VAT Notice 703) to demonstrate how they disposed of the goods to HMRC.
Exporters must also make an import declaration for any goods returned to the UK.
Therefore, with export declarations through CDS, care needs to be taken to ensure that the correct VAT declaration has been made to ensure compliance with VAT legislation.
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