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UK tax·US UK Tax Hub Tax Team

The British tax that has nothing to do with your profits

Iron trusses beneath a Victorian railway station roof, illustrating VAT registration for founders

Most American founders in Britain meet VAT registration through a letter rather than a plan. The business grew, nobody was watching a rolling total, and a threshold passed in a month that felt no different from the last one.

VAT is not a tax on what you earn. It is a tax you collect on what you sell, which means a business losing money can still be sitting on an obligation. So the trigger has nothing to do with the numbers your accountant watches most.

What is VAT registration?

It is the point at which your business starts charging VAT on its sales and handing it to HMRC. You also start reclaiming VAT on what you buy. The business becomes a collector rather than a payer.

The standard rate is 20%, with reduced and zero rates for particular goods and services.

The GOV.UK page on VAT rates sets out which rate applies where.

When does VAT registration become compulsory?

Two tests run at once, and either one can catch you. The backward test asks whether your taxable turnover over the last twelve months has gone above £90,000. The forward test asks whether you expect to pass £90,000 in the next thirty days alone.

The twelve months is a rolling window, not your accounting year.

So the month you cross can be any month, including one in the middle of a quiet year.

The GOV.UK page on registering for VAT sets out how to apply once either test is met.

TestWhat it looks atWhen to registerEffective from
BackwardTaxable turnover over any rolling 12 monthsWithin 30 days of the end of the month you went overThe first day of the second month after
ForwardThe next 30 days aloneBy the end of that 30-day periodThe date you realised

What counts towards the £90,000?

Taxable turnover means the total value of what you sell that is neither exempt nor outside the scope of UK VAT. Standard-rated, reduced-rated and zero-rated sales all count. So do goods you take for personal use, and bartered or gifted stock.

Zero-rated sales surprise people. A rate of nothing is still a taxable supply.

The GOV.UK guidance on calculating turnover lists the inclusions.

Do sales to American clients count?

Often they do not, and that single point changes the picture for many founders here. Taxable turnover excludes supplies that fall outside the scope of UK VAT, and services supplied to business customers abroad frequently sit there under the place-of-supply rules.

Whether a particular sale is out of scope depends on what you sell and to whom.

So a consultancy billing New York may sit well under the threshold while its bank balance suggests otherwise.

Does having no UK establishment help?

It does the opposite, and this catches people running a British operation from abroad. A business with no establishment in the United Kingdom has no threshold at all. It must register once it makes taxable supplies here, whatever the amount.

The threshold is a concession to established businesses, not a universal allowance.

In our practice this is the version of the rule that most often arrives as a surprise.

What happens if you register late?

You owe the VAT anyway. HMRC backdates the registration to the date you should have registered, and the VAT on sales made since then becomes payable whether or not you charged it to anyone.

That is the expensive part. Chasing old customers for an extra fifth is rarely successful.

Penalties and interest then sit on top of a bill you have already funded yourself.

So the thirty-day deadline is the one to diarise. VAT registration is cheap to do on time and expensive to do late.

Is voluntary VAT registration ever sensible?

Sometimes, and it turns on who your customers are. Registering below the threshold lets you reclaim VAT on purchases, which suits a business buying a lot and selling mainly to other registered businesses. Those customers reclaim your VAT, so your prices stay competitive.

Selling to consumers is different, because your price effectively rises by a fifth.

A business making mostly zero-rated sales often registers voluntarily and reclaims steadily.

There is a credibility argument too. Some larger customers treat a VAT number as a sign of scale, though that is a commercial judgement rather than a tax one.

What does VAT registration involve month to month?

Returns, usually quarterly, filed through compatible software under Making Tax Digital. You keep digital records of sales and purchases, and the software submits the figures rather than a person typing them into a website.

Payment follows the return on a set timetable.

So the real cost is systems and discipline rather than the tax itself.

Self Assessment continues alongside it, on a different timetable entirely. The GOV.UK guidance on Self Assessment covers that side, and we walk through the sign-up in registering for Self Assessment.

Does any of this reach your American return?

Barely, and that is the useful answer. VAT is a tax on consumption rather than on income, so it produces no foreign tax credit against American tax. It is not your tax in any meaningful sense, because you collect it from customers and pass it on.

Your business accounts should therefore run net of VAT once registered.

Publication 54 covers the wider position for Americans abroad, and the IRS page for Publication 54 links the current edition.

Watch the gross figures in your bookkeeping. Reporting VAT-inclusive sales as income overstates your profit on both returns.

How do the two systems compare here?

They barely overlap, which is why founders miss it. American sales tax sits at the point of sale and varies by state. VAT runs through every stage of a supply chain, with businesses reclaiming what they paid.

There is no federal equivalent to reason from.

So instinct built in America is not a reliable guide in Britain.

One habit does carry across. Keep the tax you collect somewhere separate from your working capital, because it was never yours to spend.

FeatureUK VATUS sales tax
Who charges itEvery registered business in the chainUsually the final seller
Reclaimable by business buyersYesGenerally no, exemption certificates instead
Set byOne national systemStates and localities
Creditable on a US returnNo, it is not an income taxNo

What about selling digital products?

What about selling digital products? — vat registration

Digital sales follow their own place-of-supply rules, and they are unforgiving. Where you sell automated digital services direct to consumers, the country that taxes the sale is usually the customer's country rather than yours.

That can create obligations outside Britain entirely, at thresholds far lower than £90,000.

Take proper advice before scaling a direct-to-consumer digital product across borders. The rules reward planning and punish discovery.

Does VAT registration change your pricing?

It changes what the customer pays, and whether that matters depends on who they are. A registered business customer reclaims the VAT you add, so your price to them is unchanged in real terms.

A consumer cannot reclaim anything. Adding 20% either raises your price or cuts your margin.

So model the two customer types separately before choosing a registration date you control.

Which schemes are worth knowing about?

Several exist, and they change the administration rather than the liability. Cash accounting lets you account for VAT when money moves rather than when you invoice, which helps businesses waiting to be paid. Annual accounting reduces the number of returns.

Flat rate schemes simplify the calculation for smaller businesses.

Each has eligibility limits, and the right one depends on your margins and your customers.

What about deregistering?

It is possible once turnover falls, and it is not automatic. You apply, and HMRC cancels the registration from an agreed date. Until then the returns keep coming, so a dormant registration still needs filing.

There can be a charge on stock and assets you keep.

Deregistering and re-registering repeatedly is not a strategy worth building on.

Plan the date rather than drifting into it. A cancellation agreed in advance is far tidier than one negotiated after a missed return.

Getting VAT registration right, step by step

Work through this before the threshold is in sight rather than after. Most of the expensive mistakes here come from reacting late.

  1. Identify which of your sales are taxable, exempt or outside the scope.
  2. Track a rolling twelve-month total of the taxable ones, updated monthly.
  3. Set an internal alert well below £90,000 so the decision is never urgent.
  4. Check whether you have a UK establishment at all, because that removes the threshold.
  5. Decide on voluntary registration if most customers are VAT-registered businesses.
  6. Choose your scheme and get compatible software in place before the first return.
  7. Keep the American accounts net of VAT, so nothing double counts.

What records does VAT registration require?

Digital records of every sale and purchase, held in software that can file for you. HMRC expects the figures to flow from your records to the return without being retyped along the way.

Keep invoices showing your VAT number, the rate applied and the amount charged. Customers need them to reclaim.

Our clients who set the bookkeeping up properly at registration spend a fraction of the time on it afterwards.

An illustrative example

Take an American developer in London invoicing £120,000, of which £95,000 goes to business clients in the United States. On the face of it she is well over the threshold.

Once the overseas supplies are excluded as outside the scope, her taxable turnover is £25,000 and no registration is required.

She might still register voluntarily to reclaim VAT on equipment. This example is illustrative rather than advice, and the place-of-supply analysis would need doing properly on her own contracts.

Common mistakes

First, watching the accounting year instead of a rolling twelve months.

Second, treating zero-rated sales as if they were outside the scope. They count.

Third, assuming a threshold exists when the business has no UK establishment.

Fourth, trying to claim VAT as a foreign tax credit on an American return. It is not an income tax, and it does not qualify.

Fifth, splitting one business across two entities to stay under the threshold. HMRC looks at whether the separation is real, and an artificial split rarely survives the question.

What if you also trade through a company?

Then the registration belongs to the company, not to you. VAT attaches to the business making the supplies, so a sole trade and a company are separate for this purpose, each with its own threshold.

Splitting one business artificially between the two to stay under the threshold invites a challenge.

HMRC can treat connected businesses as one where the separation is not genuine.

How US UK Tax Hub helps

We look at what you actually sell and to whom, because that decides the threshold question before any registration date does. Then we set up the tracking so the next twelve months are never a surprise.

That work sits beside our UK Self Assessment service, and our note on going freelance in Britain covers the wider setup.

This article is general information, not personal tax advice. Talk to us about your own sales.

Last reviewed . Tax thresholds and rates change annually — check the figures against the current tax year.

Questions this raises for readers

It is £90,000 of taxable turnover. Two tests apply: whether your taxable turnover across any rolling twelve months has passed that figure, and whether you expect to pass it within the next thirty days on its own. Either test can trigger the obligation, and the rolling window is not your accounting year.


No, and that is the most costly misunderstanding here. Turnover means the value of what you sell before any costs, so a business making a loss can comfortably pass the threshold. VAT is a tax on transactions rather than on results, which is why profitability never enters the test.


Often not, though the analysis needs doing rather than assuming. Taxable turnover excludes supplies outside the scope of UK VAT, and services to business customers abroad frequently fall there under place-of-supply rules. Which of your sales qualify depends on what you supply and to whom.


HMRC backdates the registration to when you should have registered, and the VAT on sales since that date becomes payable. Because you did not charge customers at the time, you usually fund it yourself. Penalties and interest may follow, so disclosing promptly is better than waiting to be found.


No. The foreign tax credit applies to income taxes, and VAT is a consumption tax collected from your customers. It never belonged to you, so it produces no credit and no deduction against American income tax. Your business figures should simply run net of it once registered.


It depends entirely on your customers. Where most of them are VAT-registered businesses, they reclaim what you charge, so registering costs your prices nothing and lets you recover VAT on purchases. Where you sell to consumers, registering effectively raises your price by a fifth unless you absorb it.


Not if the business has no establishment in the United Kingdom. Businesses without a UK establishment must register once they make taxable supplies here, whatever the value. The threshold is a concession for established businesses rather than a universal allowance, and overseas founders regularly miss that distinction.

Near the VAT threshold, or past it?

Send us a breakdown of your sales by customer and country, and we will tell you where the threshold really sits for your business and what to do next, at a fixed fee agreed first. General information, not personal tax advice.

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