Two Rules Decide What You Keep When You Sell Digital Products in Ireland

A music teacher in Laois spent last winter recording twelve short videos on the tin whistle. Where the fingers go. How to get a clean note instead of a sound like a kettle in distress. Three tunes you could play at a session without anyone wincing. She priced the set at forty euro, put it up for sale, and had buyers inside a fortnight. This is a composite of conversations I have had more than once with people selling something digital for the first time, so read the details as illustrative rather than one named customer.

Then the email arrived. Day nine, one buyer wanted her money back. She had already downloaded all twelve files.

The teacher's instinct was to say no. My advice was to pay it, because under Irish law that buyer was almost certainly entitled to the refund, and the reason had nothing at all to do with the quality of the course.

The forty euro was never the problem

One refund is an annoyance. The gap underneath it is the thing that costs money, because it does not sit under one sale. It sits under every sale she had already made and every sale she would make next.

Think about what that means for a product with no marginal cost. She could sell four hundred copies of that course over a year, bank the money, spend it, and every single one of those buyers would still hold a live right to a full refund after consuming the entire thing. Nothing has to go wrong for that to hurt. A competitor releasing a free version, a bad week, a screenshot of the course doing the rounds in a WhatsApp group, and the refund requests arrive together while the money is already in the business account.

That is the quiet risk with digital products. There is no van to recall, no stock to take back, no way to un-download a video. The only thing standing between you and an open-ended refund window is the wording at your checkout.

Three boxes that close the refund window

The Consumer Rights Act 2022 sets out when the cancellation rules stop applying. For paid digital content that is not supplied on a physical medium, section 111(e) removes the right to cancel only where three things are true together: supply of the digital content has begun, the consumer provided prior express consent to the supply beginning during the cancellation period and an acknowledgement that he or she will thereby lose the right to cancel, and the trader provided confirmation of the contract ^[1].

Read that again, because the middle condition is doing all the work. Consent and acknowledgement are two separate things. A buyer agreeing to instant access is not the same as a buyer confirming they understand that instant access ends their right to a refund.

In practice, this is a tick box and an email.

The tick box sits at your checkout, before payment, and it has to say both parts in plain language: you agree the download starts immediately, and you accept that this means you lose your 14-day right to cancel. The email is the confirmation of the contract, which the Act separately requires to carry confirmation of that acknowledgement ^[1]. The Competition and Consumer Protection Commission is blunt about the starting position for any online sale of digital content, which is that consumers have a withdrawal period of 14 days from when the contract was agreed ^[2]. You are not disabling a consumer right by adding that box. You are meeting the conditions the law sets for the right to fall away.

For the teacher, this took about twenty minutes to fix. That is the whole story of the first rule. Twenty minutes of checkout wording decided whether a year of sales was final or provisional.

The VAT is due where your buyer is, not where you are

The second rule is the one that arrives quietly a year later, usually the week an accountant asks a question nobody has an answer to.

When you sell a downloadable course or a template pack, you are generally making an electronically supplied service. Revenue defines that as a service delivered over the internet, heavily dependent on information technology, essentially automated, involving minimal human intervention, and not viable in the absence of that technology ^[3]. A recorded course delivered by an automatic download link fits neatly. So does a PDF pattern, a set of photo presets, a spreadsheet template.

For those services sold to consumers, the place of supply is where the customer is established, has their permanent address, or usually resides ^[3]. Not where you sit. Not where your website is hosted.

Revenue softens that with a threshold, and the detail of it matters. Where the value of these services supplied to non-taxable persons is less than 10,000 euro in the current and preceding calendar year, the supplies stay subject to domestic VAT ^[4]. That figure is exclusive of VAT, and it only applies while you are established in a single member state. Once you exceed it, the exception is gone, and VAT falls due in the member state where your customer is based on every supply after that point. From there you either register in each of those countries or use the One Stop Shop through Revenue Online Service to declare it all in one return ^[4].

So what does that mean for a small seller? Mostly reassurance. If you sell a few hundred euro of downloads a year, and your buyers are largely at home, you are nowhere near this. The point of knowing the number is that digital products scale in a way physical ones do not. One good mention in a hobbyist forum abroad and a course that took two years to earn 3,000 euro can do 12,000 euro in a quarter, most of it cross-border, most of it now taxable somewhere else. Sales you cannot see coming create obligations you did not plan for. That is worth a diary note at, say, 7,000 euro rather than a scramble at 10,001 euro.

One more piece of small print worth knowing before you get clever. A supplier under the threshold can choose to apply the general place of supply rules anyway, and Revenue binds that decision for two years ^[4]. Opting in early is a real option. Opting in and out to suit a good quarter is not.

Not everything digital carries the same rate

This is where people assume a single rate and get it wrong in both directions.

Revenue applies the zero rate of VAT to e-books and audiobooks from 1 January 2024, and to e-newspapers from 1 January 2023, with exclusions for publications that are wholly or predominantly devoted to advertising, or that consist wholly or predominantly of audible music or video content ^[5]. Electronic services generally carry the standard rate, currently 23%.

Put those side by side and the practical consequence is obvious. A downloadable book and a video course are not automatically the same supply, so a seller with both may be dealing with two different treatments in one shopping cart. And because Revenue warns that supplies combining electronic and other elements must be considered case by case ^[3], the classification of a live weekly class taught by a human over video is a genuinely different question from a recorded one. Ask your accountant that question before you build the pricing, not after.

What the platform's cut actually buys

The fair version of this comparison starts by admitting the platforms are not selling nothing.

What is at stake	Selling through a creator platform	Selling from your own website
Cut on each sale	Platform fee on every sale, forever, or a monthly subscription to reduce it	Payment processing only
Who accounts for the VAT	The platform, as merchant of record	You, through Revenue
Who holds the customer list	The platform	You
Who controls the consent wording	The platform's checkout	You

Take the fees first. Gumroad's published pricing puts its cut at 10% plus a fixed 50 cent charge on a direct sale, rising to 30% for sales it sends you through its own marketplace, and it states that since 1 January 2025 it handles the seller's tax obligations. Teachable's published plans start at 39 dollars a month with a 7.5% transaction fee on the entry tier, with that transaction fee removed on the higher monthly plans. Read those two shapes closely and you can see the model. You pay a percentage of every sale you ever make, or you pay a subscription that is only rational once your volume is high, and often both for a while.

On a forty euro course, ten percent plus a fixed fee is roughly a fiver a sale. Sell three hundred copies and the platform has quietly taken more than a decade of what a full website would cost to run. The maths only gets worse as the product succeeds, which is a strange thing to sign up for.

And now the concession, because a comparison that concedes nothing is just an advertisement.

If your buyers are genuinely scattered across a dozen countries and your volume is over that threshold, a merchant of record platform is doing real, specialist work for its cut. It calculates the right rate in each country, collects it, remits it, and files it. That is not a feature you can bolt onto a website. If you are a one-person operation with no accountant and a worldwide audience, paying a percentage to make that entire problem belong to somebody else is a defensible commercial decision, and I have told people to do exactly that. The trade is that you are renting your storefront, your margin, and your consent wording from a company whose terms you do not set.

The asset the fee never buys back

The teacher's real problem with the platform route was not the percentage. It was the list.

When a stranger buys a course through a marketplace, the marketplace has a customer and you have a payout. You often cannot email that person to tell them about the intermediate course you spent the summer recording. The economics of digital products depend almost entirely on selling a second and third thing to someone who already trusts you, and a platform that stands between you and that person is taxing your future, not just your present. This is the same pattern as taking payments on your own website rather than through a platform that takes a cut: the money is the visible part, the relationship is the valuable part.

Owning the list also means you own the follow-up. That matters more for digital goods than physical ones, because your buyer's only proof of purchase is an email in their inbox.

What she actually set up

She kept it deliberately unremarkable. A WordPress site with a shop section, the twelve videos hosted and delivered by a download link on payment, a checkout with the two-part consent box, and an order confirmation email that repeats the acknowledgement in writing. Nothing exotic. The whole thing was a WordPress build on managed hosting with design, hosting, SSL, backups and support included for 60 euro a year, which for a business selling a forty euro course means the platform is paid for by sale number two, not by a percentage of sale number four hundred.

The one piece that took actual thought was the paperwork side. She now records the country of every buyer at checkout, keeps a running total of cross-border sales against that 10,000 euro line, and sends the confirmation email automatically rather than by hand. Her privacy notice and terms were updated at the same time, which is the boring companion job to any change like this and one I would fold into a wider review of the legal pages an Irish business website needs.

Selling something with a defined lifespan attached, like a course with a start date, brings its own version of this same discipline, which is much closer to the rules that govern gift vouchers and the promise they carry than most sellers expect.

What your own website will not do for you

Now the honest limitation, because I would rather you hear it from me than from an accountant in March.

Your website will not file your VAT return. It can record the customer's country, apply a rate you configure, and hand you a clean export at the end of the quarter. It will not decide whether your product is an e-book or a video service, it will not register you for the One Stop Shop, and it will not notice on your behalf that you crossed a threshold in October. That work stays yours, or your accountant's. A merchant of record platform genuinely takes it away, and that is precisely what its percentage is buying.

Know which of those two deals you are signing. Both are respectable. Only one of them keeps getting more expensive as you get better at selling.

Where that leaves the whistle course

She refunded the day-nine buyer without an argument, added the checkbox that afternoon, and has not had a contested refund since. The course still sells slowly, the way small digital products do, which is to say most weeks nothing much happens and occasionally a good week pays for the year.

The lesson she took from it was not really about tax or consumer law. It was that a digital product is finished when the paperwork around it is finished, not when the last video is exported. Everything you sell after that point is genuinely yours to keep.

If you are sitting on a file you could sell this month, the sequence is short: work out what the thing is for VAT, put the two-part consent in front of the payment button, and make sure the confirmation email says the same thing in writing. Then go and sell it.

Frequently Asked Questions

Does the 14-day cancellation right apply to a digital download?

Yes, unless three things happened first. Under section 111(e) of the Consumer Rights Act 2022, the cancellation chapter stops applying to paid digital content that is not on a physical medium only where supply has begun, the consumer gave prior express consent to supply starting during the cancellation period along with an acknowledgement that this loses them the right to cancel, and the trader provided confirmation of the contract. Miss any one of the three and your buyer keeps a 14-day right to a refund even after downloading everything.

Do I charge Irish VAT on a course sold to a customer in another EU country?

It depends on your cross-border total. Revenue applies a 10,000 euro place of supply threshold to telecommunications, broadcasting and electronically supplied services sold to consumers. Below that figure across the current and preceding calendar year, and while you are established in only one member state, the supplies stay subject to domestic VAT. Once you pass it, VAT is due in the country where your customer is based, and you either register there or declare it through the One Stop Shop in Revenue Online Service.

What VAT rate applies to an e-book compared with a video course?

They are not necessarily the same. Revenue applies the zero rate to e-books and audiobooks from 1 January 2024, and to e-newspapers from 1 January 2023, with exclusions for publications that are wholly or predominantly advertising or that consist wholly or predominantly of audible music or video content. Electronic services in general carry the standard rate. Confirm the classification of what you actually sell with your accountant, particularly if you sell both.

Is a live online class an electronically supplied service?

Not automatically. Revenue's definition turns on the supply being essentially automated, involving minimal human intervention, and not viable without the technology. A pre-recorded course delivered by an automatic download link sits inside that. A live class taught by a person over video does not obviously do so, and Revenue notes that supplies mixing electronic and other elements must be considered case by case.

Do I need to register for VAT at all to sell digital products?

Registration and place of supply are separate questions. Revenue currently sets the registration threshold at 42,500 euro for persons supplying services only and 85,000 euro for persons supplying goods, with a separate 10,000 euro threshold for distance sales and cross-border electronic services. Sellers below the registration threshold may not need to register, but the cross-border rules still decide which country would tax the supply once you are.

Can I sell digital products from a normal WordPress site, or do I need something specialised?

A standard WordPress site with a shop section handles digital goods well: the file is attached to the product, the download link is released on payment, and the confirmation email goes out automatically. The parts that need attention are not technical. They are the consent wording at checkout, the record of where each buyer is based, and the VAT treatment of the product itself.

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