You're Not Based in the UK — So the £90,000 VAT Threshold Doesn't Apply to You

Ask most sellers what the UK VAT registration threshold is, and they'll tell you: £90,000. It's a well-known number, and it's correct — for a UK-established business. If your business is established anywhere else — a company registered in Germany, France, Ireland, the US, or elsewhere — that number simply does not apply to you, and assuming otherwise is one of the more expensive mistakes an Amazon seller can make.

Two different rules, and only one of them mentions a threshold

UK-established sellers register for VAT once their taxable turnover exceeds £90,000 in any rolling 12-month period. This is the rule everyone's heard of, and it's genuinely a threshold — stay under it, and registration isn't required yet.

Non-established taxable persons (NETPs) — the term HMRC uses for sellers whose business is established outside the UK — get no threshold at all. Registration is required from the first taxable sale, whatever the amount. A seller based in France doing €8,000 a year into the UK market is in exactly the same registration position as one doing £500,000, because the £90,000 figure was never designed with them in mind. It's a threshold for UK businesses deciding when to start charging VAT domestically, not a general small-seller exemption.

This distinction trips up a specific, common profile: a seller established in an EU country, or in the US, who's watching their UK Amazon sales grow, doing the mental math against £90,000, and concluding they have runway before they need to think about UK VAT. They don't. The runway was never there.

The online marketplace rule complicates things further — in a good way, mostly

Since January 2021, the UK treats Amazon as the "deemed supplier" for VAT on certain sales — specifically, sales to UK consumers where the seller is based outside the UK and the goods are located in the UK (in Amazon UK FBA, for instance) at the point of sale. On those qualifying sales, Amazon charges and remits the VAT itself, not the seller.

This is genuinely useful, but it's easy to over-read. It does not mean the underlying registration requirement disappears — a non-UK seller is still an NETP and still needs to register from their first sale. What it changes is which sales the seller charges VAT on directly. Registration is still needed to reclaim import VAT paid when goods enter the UK, to handle any B2B sales the deemed-supplier rule doesn't cover, and simply because the NETP registration rule doesn't have an exception for "but Amazon handles some of my VAT already."

What this looks like in practice

A seller based in Italy, selling into the UK through Amazon FBA with stock held in a UK fulfillment center:

• Is an NETP, with no £90,000 cushion.
• Should register for UK VAT before or immediately upon their first UK sale, not once revenue reaches some threshold.
• Will likely have some sales where Amazon is the deemed supplier and charges VAT directly to the customer — but still needs a UK VAT number for import VAT recovery and any sales that fall outside that deemed-supplier scope.
• Files UK VAT returns, normally quarterly, and needs Making Tax Digital-compatible record keeping once registered.

Swap Italy for Poland, the US, or any other non-UK jurisdiction and the analysis is identical. The one variable that actually matters is whether the business is established in the UK — not its size, not its revenue, not how long it's been selling there.

The one question to ask before anything else

Before estimating UK VAT exposure at all: where is this business legally established? Everything else — the threshold, the NETP rule, the deemed-supplier mechanics — branches from that single fact. Get it backwards, and every other calculation that follows is built on the wrong rule.

As with any VAT position, current thresholds and HMRC's specific rules should be confirmed before acting — the £90,000 figure has moved before (it was £85,000 until April 2024) and the deemed-supplier mechanics are the kind of detail worth double-checking with a UK VAT specialist rather than assuming they've stayed exactly as described here.

Official sources

• HMRC: when UK and overseas businesses must register for VAT
• HMRC: selling goods through an online marketplace or directly to UK customers

This is general information based on current publicly available UK VAT rules, not personalized tax advice. Thresholds and HMRC guidance change — confirm current requirements with a licensed UK VAT advisor before registering, deregistering, or filing anything.