UK VAT registration for overseas companies: how to apply

An overseas company with no UK establishment must register for UK VAT within 30 days of making, or first expecting to make, a taxable supply in the UK, whatever its turnover. It applies through HMRC's online service, itself or through a UK agent. HMRC asks applicants to chase only after 40 working days without a reply.

This guide is about how to apply. Whether you must register in the first place, the place of supply rules and the £90,000 threshold that applies only to UK-established businesses are covered in our guide to UK VAT for non-resident and overseas businesses. Every rule below was checked on gov.uk, in HMRC's VAT Notice 700/1 and manuals, and on legislation.gov.uk on 31 October 2026, after the Budget of 28 October 2026.

Who has to register: the short version

HMRC calls a business with no UK establishment a non-established taxable person, or NETP. A business has a UK establishment if its essential management decisions and central administration happen in the UK, or if it has a permanent physical presence here with the people and equipment to make or receive supplies. VAT Notice 700/1 says a registered, serviced or virtual office alone is not enough.

An NETP has no registration threshold. It must tell HMRC within 30 days of making a taxable supply in the UK, of any value, or within 30 days of first expecting to make one in the next 30 days. The £90,000 threshold, unchanged by the Budget for April 2026 and April 2027, is only for UK-established businesses.

Notice 700/1 lists cases where an NETP may not need to register: all its UK sales are zero-rated, all its UK sales go through an online marketplace to consumers, or all its UK sales are to VAT-registered businesses in Great Britain that account for the VAT under the reverse charge. If every UK sale is exempt from VAT, it cannot register at all.

A change announced for April 2027. At the Budget on 28 October 2026 the government said it will restrict the reverse charge on services from overseas so that it only applies when the UK business customer is VAT registered. If the change goes ahead as announced, an overseas supplier selling services to a UK business that is not VAT registered will have to charge and account for UK VAT itself. The legislation is due in Finance Bill 2026-27 and is not yet law. If you sell services to small UK businesses, plan for UK registration before April 2027.

What to prepare before you apply

Gather these before you start. The online service lets you save your entry and come back to it, but missing details still slow the application down.

• A Government Gateway user ID. You need one to sign in. If you do not have one, you create it the first time you sign in.
• Your principal place of business. HMRC registers an NETP at the address where orders are received and the business is run day to day. It must be outside the UK and should not be a third-party address such as a mail-forwarding service or a registered office provider.
• Your registration date. This is the date of your first UK taxable supply, or the date you first expected to make one. HMRC registers you from the date you became liable, whenever you apply.
• A turnover estimate. The application asks for your expected taxable turnover for the 12 months from your registration date. The previous 12 months are a sensible starting point.
• Company and bank details. For a UK limited company, gov.uk lists the company registration number, bank account details, a Unique Taxpayer Reference (UTR) and turnover figures. HMRC's manual says neither the online nor the paper application has a field for an overseas bank account (see the FAQ for how repayments work).
• Your agent's or tax representative's details, if you are appointing one.

HMRC checks every application and may write asking for more information before it issues a number, which adds time. Keep your certificate of incorporation, a director's identity document and your first UK contract or invoice to hand so that you can answer quickly.

How to apply: online, through an agent, or on paper

Online. VAT Notice 700/1 names HMRC's online VAT registration service as the route for an NETP making supplies in the UK. You sign in, answer the questions about the business and its UK supplies, and add any extra forms the service asks for.

Through an agent. A UK agent can make the application for you through its agent portal. The company is still responsible for the accuracy of what is submitted.

On paper. Form VAT1 is for businesses that cannot use the online service, for example because of age, health, disability or location, a religious objection to computers, or no internet access. Some cases, such as registering an overseas partnership, also use paper. You phone the VAT helpline, HMRC asks why you need a paper form, and you may only apply on a form HMRC has sent you. Paper applications from NETPs go to BT VAT, HM Revenue and Customs, BX9 1WR, and gov.uk says postal applications usually take longer.

If all your UK sales are zero-rated, you can apply through the same online service for exemption from registration instead.

VAT agent or tax representative: who carries the liability

An NETP can deal with HMRC itself, appoint an agent, or appoint a tax representative (HMRC also says VAT representative). The difference is liability.

	VAT agent	Tax representative
Liable for your VAT debts?	No. HMRC cannot pursue an agent for them	Yes. Jointly and severally liable for VAT, and for penalties on returns it submits
Legal basis	An ordinary appointment by the company	Section 48 of the VAT Act 1994, which requires a UK-established person
How appointed	Agent portal, or a signed letter of authority	Details given in the online application, plus form VAT1TR, which both parties complete and HMRC's manual says must be sent within 30 days of the appointment
Can HMRC refuse?	HMRC can decline to deal with a particular agent	HMRC can refuse or cancel a representative who is not fit and proper

When HMRC can require a representative. Section 48 lets HMRC direct an NETP to appoint a UK-established tax representative if it is established in a country with no VAT mutual assistance arrangements with the UK. Notice 700/1 confirms that HMRC cannot direct NETPs based in countries where those arrangements exist. HMRC can also ask any NETP for a security, and it can direct an overseas seller that does not meet its VAT obligations to appoint a representative.

Because a representative shares liability, HMRC's manual says it should only accept one it is confident could meet the principal's VAT debts, and it will not accept terms that limit that liability. A representative therefore takes on your VAT risk as well as your paperwork. If HMRC has not directed you to appoint one, an agent is usually enough. If you appoint neither, you must register on time, keep the records, file returns and pay the VAT yourself.

How long it takes, and what to do while you wait

HMRC does not publish a fixed processing time for NETP applications. VAT Notice 700/1 says HMRC will contact you either with your VAT registration number or to say it needs more information. If you have not heard after 40 working days, contact HMRC's VAT Registration Service to check it has your application. HMRC asks you not to chase before then, because it can delay processing. Its "check when you can expect a reply" tool, updated weekly, shows current waiting times.

The wait does not pause your liability. You owe VAT from your registration date even if the number has not arrived. gov.uk says you cannot show VAT on invoices until you have the number, but you can raise your prices to cover it. Once the number arrives, you reissue those invoices showing the VAT, and a VAT-registered customer can then reclaim it.

If you apply late, HMRC still registers you from the date you should have been registered. You account for VAT from that date even if you did not charge it, and HMRC can add a penalty for failing to notify on time.

After registration: Making Tax Digital, returns and penalties

HMRC sends by post your 9-digit VAT registration number, your registration date, details of your first return and how to set up a business tax account. It also signs the business up to Making Tax Digital (MTD) for VAT unless it is exempt. Sign up for a VAT online account as soon as the number arrives.

• Digital records and software. Under MTD you keep digital records and submit returns through compatible software.
• Return periods. Returns are normally quarterly. If you expect to reclaim more VAT than you charge, you can ask for monthly returns.
• Deadline. The return and the payment are usually due one calendar month and 7 days after the end of the period, and the money must reach HMRC by then.
• Late returns. Each late return earns a penalty point. At the threshold (4 points for quarterly returns, 2 for annual, 5 for monthly) you pay £200, and another £200 for each later late return while you stay at the threshold.
• Late payment. A first late payment penalty applies once a payment is 16 or more days overdue, and a second from 31 days. Interest runs from the first day.
• Changes. Tell HMRC within 30 days if your business name, main address or agent changes.

Your return is also how you reclaim UK VAT: if HMRC owes you money, the return is your repayment claim. Our guide to registering an overseas company for UK corporation tax covers the separate HMRC registration a company needs if it has a UK permanent establishment or UK property.

How Cosmos helps. Cosmos handles UK VAT registration and VAT returns for companies based outside the UK: we prepare the application, set up MTD-compatible records and file each return. If HMRC requires a tax representative, we arrange one through a UK partner. We hold the deadlines on one calendar with the rest of your group's filings and quote a fixed fee upfront. We also check whether changes such as the April 2027 reverse charge reform affect your UK sales. See Cosmos tax services or book a call.

FAQ

Is there a UK VAT registration threshold for overseas companies?

No. A business with no UK establishment must register for UK VAT if it makes any taxable supply in the UK, whatever the value, or expects to in the next 30 days. The £90,000 threshold applies only to UK-established businesses.

How long does UK VAT registration take for an overseas company?

HMRC does not publish a fixed time. VAT Notice 700/1 says to contact the VAT Registration Service if you have heard nothing after 40 working days, and not before. It takes longer if HMRC asks for more information.

Do I need a UK bank account to register for UK VAT?

No. HMRC's manual says the application has no field for an overseas bank account. Once registered, an NETP without a UK bank account can ask for repayments to an overseas account in the company's name that accepts sterling. Otherwise HMRC sends a payable order.

Do I need a UK VAT representative?

Only if HMRC directs you to appoint one. It can do so if your business is established in a country with no VAT mutual assistance arrangements with the UK. Otherwise you can deal with HMRC yourself or appoint an agent.

What is the difference between a VAT agent and a tax representative?

A tax representative is jointly and severally liable for your UK VAT debts and must be based in the UK. An agent acts for you but is not liable for your VAT, so HMRC cannot pursue an agent for what you owe.

Can an overseas company register for UK VAT on paper?

Only if it cannot use the online service or falls in a specific case, such as an overseas partnership. You phone HMRC to request form VAT1, and postal applications usually take longer than online ones.

Do overseas companies have to use Making Tax Digital for VAT?

Yes, unless exempt. HMRC signs every newly registered business up to Making Tax Digital for VAT, so you keep digital records and file returns through compatible software, normally every quarter.