How can you get a VAT refund in the United Kingdom?

Can you reclaim the VAT paid in the United Kingdom?

You can reclaim UK VAT if you are a business not established in the United Kingdom and you are not required to obtain a VAT number in the United Kingdom. That is the starting point. HMRC reserves the VAT65A procedure for foreign businesses that bear UK VAT on business expenses but do not themselves have to account for UK VAT.

The scheme covers businesses established in the European Union and businesses established outside the EU. Since Brexit, a French, Belgian, German or Spanish company no longer goes through its member state's electronic refund portal to reclaim the VAT paid in Great Britain. It applies directly to HMRC.

What conditions must you meet to apply for the refund?

HMRC requires that your business be established outside the United Kingdom and that it not carry out transactions that would require it to register for UK VAT. The logic is simple: the VAT65A serves to refund VAT borne by a non-registered foreign business, not to replace a UK VAT return.

To be eligible, you must in practice meet these conditions:

• be registered as a business in your country of establishment;
• have no seat, fixed establishment or residence in the United Kingdom;
• not be registered, eligible or required to register for UK VAT;
• not make taxable supplies of goods or services in the United Kingdom, save for exceptions allowed by HMRC;
• use the goods or services purchased for your business activity.

A transaction may remain compatible with the refund when the VAT is due from your UK customer through the reverse charge mechanism, or when the transaction falls under specific exceptions such as certain international transport of goods. Conversely, selling goods locally in the United Kingdom, storing goods in the UK or importing as the seller can shift the case towards a registration.

Do you need to register for VAT in the UK to reclaim your VAT?

No, it is not mandatory to register for VAT in the UK to reclaim UK VAT via the VAT65A. It is actually the opposite: this procedure concerns businesses that are not registered and are not required to be.

If you simply attended a trade fair, paid for local services, incurred business travel expenses, purchased services used in the United Kingdom or bore import VAT without creating a local taxable obligation, the refund procedure may be the right route.

If you are required to register, the VAT borne is no longer recovered via the VAT65A. It is deducted in your United Kingdom VAT return, subject to UK deductibility rules. This difference is essential for e-commerce businesses, DDP sellers and regular importers.

What is the step-by-step procedure to apply for a UK VAT refund?

The refund application is prepared like a complete tax file, not like a simple administrative form. HMRC expects form VAT65A, the certificate proving your activity, the invoices and, in the case of importation, the customs documents proving the VAT paid.

1. Check your eligibility

Start by verifying that you have no establishment in the United Kingdom, that you are not registered for UK VAT and that your transactions do not make you a taxable person in the UK. If you have made sales, imported goods or worked with a marketplace, this step must be documented.

2. Define the refund period

The HMRC period runs from 1 July to 30 June of the following year. An application can cover at most this 12-month period. It cannot cover less than 3 months, unless it corresponds to the remaining balance of the annual period.

3. Gather the invoices and supporting evidence

Each invoice must identify the supplier, its VAT number, your business, the nature of the goods or services, the date, the amount excluding tax, the rate and the amount of VAT. For importations, the customs document or the evidence showing the VAT paid is required.

4. Obtain the certificate of status

For a first application, and then when the certificate expires, you must provide a status certificate issued by the official authority of your country. HMRC accepts certain electronic certificates if the issuing authority allows online verification.

5. Complete form VAT65A

Form VAT65A must be completed electronically. The list of invoices, in particular the schedule for question 9, must be typed and not handwritten. An equivalent version may be accepted if it contains the same information and the required declaration.

6. Submit the file to HMRC

You can submit electronically via the Secure Data Exchange Service, known as SDES, or send the file by post to the Overseas Repayment Unit. To use SDES before the 31 December deadline, HMRC indicates that you must request access before 30 November.

7. Track the processing

After an electronic submission, you should receive a dated receipt. If HMRC does not contact you within 6 months, you can contact the Overseas Repayment Unit with the SDES receipt. Originals must be kept, as HMRC may request them.

Which costs qualify for a VAT refund in the United Kingdom?

VAT is recoverable when it is charged on goods or services used for the needs of your business activity and no UK exclusion applies. HMRC targets in particular purchases of goods and services in the United Kingdom and the VAT paid on importations into the UK.

The standard rate of VAT in the United Kingdom is 20%. Certain goods and services fall under the reduced rate of 5%. The rate alone is not enough to decide on recovery: the nature of the expense, its business use and your UK VAT status remain decisive.

What is the minimum amount for a VAT65A application?

The minimum amount depends on the period covered by your application. HMRC sets a higher threshold for a partial period and a lower threshold for an annual period or the final balance of the refund year.

These thresholds do not replace the economic analysis of the case. A small, poorly documented application, or one made up of weak invoices, can cost more to prepare than the expected refund.

What is the filing deadline for a refund application?

The deadline is 31 December following the end of the refund period. The UK refund period runs from 1 July to 30 June. For the period ending on 30 June, the application must therefore reach HMRC no later than 31 December.

HMRC applies this date strictly. A file sent late can be refused, even if the VAT is real and the invoices are compliant. For paper filing, HMRC may request proof of posting showing that the file was posted no later than 31 December.

How long does HMRC take to refund the VAT?

HMRC states it will refund within 6 months of receiving a satisfactory application. The key word is "satisfactory": an incomplete, inconsistent or poorly evidenced file quickly ends up back in a loop of questions.

Delays generally come from four causes:

• a status certificate that is missing, expired or incomplete;
• invoices without the supplier's VAT number or without the correct name of the applicant;
• insufficient import documents;
• HMRC doubt about a possible UK VAT registration obligation.

The refund can be paid into a bank account via SWIFT or into a UK bank account. HMRC recommends SWIFT payment where available, as it is faster and more secure for foreign businesses.

Do you need a fiscal representative in the United Kingdom?

For a VAT65A application, you do not need a fiscal representative in the strict sense: you can file yourself or appoint an agent. HMRC accepts that an agent prepares and sends the application on your behalf, provided the agent is authorised by a power of attorney or a letter of authority.

The real question is therefore not "is a fiscal representative mandatory or not", but "do I need an expert to secure the right scheme?". If your case is simple, for example trade fair expenses and perfectly compliant invoices, a direct filing can work. If you import, sell, store or invoice UK customers, the analysis becomes more fiscal than administrative.

A VAT agent can in particular:

• confirm that the VAT65A is the right procedure;
• identify recoverable and excluded expenses;
• prepare the schedule of invoices;
• manage the exchanges with HMRC;
• avoid filing a refund when UK VAT registration is required.

Special cases not to miss

The UK rules change depending on whether the expense concerns Great Britain, Northern Ireland, an importation or a local sale. The United Kingdom is not a uniform VAT block for all flows since Brexit, in particular for goods involving Northern Ireland.

For goods in Northern Ireland, an EU business may be redirected to the specific refund rules linked to the Northern Ireland Protocol. For Great Britain, the HMRC VAT65A procedure is the reference for non-established businesses.

If you import goods, check that you are indeed the owner of the goods at the time of importation. HMRC conditions the recovery of import VAT on having the right to dispose of the goods as owner.

If you have invoiced a UK customer, also check whether your transaction should have been declared in the UK. The article on invoicing a UK customer helps distinguish DDP invoicing, B2B sales, B2C sales and cases where UK VAT must be collected.

Checklist before filing your VAT65A application

A complete file is checked before sending, not after HMRC's follow-up. Use this checklist before any filing.

• Your business is established outside the United Kingdom.
• You have no fixed establishment or seat in the United Kingdom.
• You are not registered for UK VAT.
• You are not required to register for UK VAT.
• The period applied for respects the 1 July to 30 June calendar.
• The minimum amount is reached.
• Form VAT65A is complete and typed.
• The status certificate is valid and consistent with the invoices.
• The invoices mention your business and the supplier's VAT number.
• The import documents prove the VAT paid, if applicable.
• The originals are kept.
• SDES access has been requested before 30 November if you are aiming for an electronic filing before 31 December.

Need support to reclaim your VAT in the United Kingdom?

Reclaiming UK VAT is an accessible but demanding procedure: a wrong choice between the VAT65A and UK VAT registration can cost several months.

Eurofiscalis helps you check your eligibility, prepare your HMRC file and secure your UK flows. Contact our team to audit your invoices and choose the right procedure before the 31 December deadline.

Official sources

• HMRC, VAT Notice 723A: https://www.gov.uk/guidance/refunds-of-uk-vat-for-non-uk-businesses-or-eu-vat-for-uk-businesses
• HMRC, form VAT65A: https://www.gov.uk/government/publications/vat-application-for-vat-refund-by-a-business-person-not-established-in-the-community-vat65a
• HMRC, VAT Notice 700/1: https://www.gov.uk/government/publications/vat-notice-7001-should-i-be-registered-for-vat/vat-notice-7001-should-i-be-registered-for-vat