VAT registration delays

Mar 08, 2021

At a meeting of the TALC Indirect subcommittee last week, the CCAB-I raised concerns on behalf of members in relation to delays in processing VAT registration applications and the commercial difficulties of overcoming the “intend to trade” test in genuine cases. The CCAB-I requested that Revenue provide a list of items acceptable as evidence of an intention to trade.

The Tax and Duty Manual – Part 38-01-03b – Guidelines for VAT Registrations, is being reviewed and members feedback on the manual is welcomed. If you wish to provide feedback, please email

The CCAB-I also raised member queries on the issue of a UK business with an Irish VAT registration exporting goods from GB to ROI on delivery duty paid (DDP) terms, in relation to the associated VAT implication for the Irish VAT registered customer.

Revenue confirmed such cases give rise to two separate transactions for VAT:

  1. The import Irish VAT, and
  2. Domestic VAT.

On the arrival of the goods in Ireland, the UK business will use its Irish VAT number to pay over the import VAT or use the postponed method of accounting. The Irish business supplying the goods to the end user in Ireland will charge Irish VAT at the appropriate rate. The technical basis for this is that the place of supply is Ireland, as the goods are located in Ireland when the transfer of ownership takes place for VAT purposes.