VAT Update: Telecommunication services and MOSS 2015

Tuesday, June 17, 2014

by Nick Ryan

To summarise, with effect from 1 January 2015 the place of supply of telecommunications, broadcasting and other electronically delivered services or digital services when supplied to consumers will shift to the place where the consumer resides. Therefore, for VAT purposes, all businesses making such supplies will be required to register for VAT in each EU Member State where supplies are made. Alternatively the business can avail of the voluntary scheme, the mini one stop shop (“MOSS”), whereby the business is only required to register in one EU Member State and accounts for VAT at the various rates per jurisdiction under this one registration.

I understand that during a recent conference on this forthcoming change HMRC confirmed that only businesses currently registered for VAT in the UK will be entitled to avail of the scheme. This places the smaller businesses in the UK that are not registered for VAT at a disadvantage as although they may be ineligible for registration in the UK they will, at the same time, have an requirement to register in other EU Member States as there is no VAT registration turnover threshold for the other EU jurisdictions thus forcing them into the VAT net.Therefore the smaller business will have to consider registering for VAT voluntarily in the UK to avoid multiple jurisdictional registrations. It is not clear why HMRC are applying a discriminatory approach to the application of MOSS and whether the same approach is being taken by other tax authorities. Considering the VAT registration threshold is set in order for the smaller business to avoid the administrative costs of being registered for VAT and the other burdens it can bring with it this approach by HMRC appears a contradiction in thought.

If you have any questions about this topic or have a particular issue that you wish to discuss then please contact Nicholas Ryan at

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