Selling to UK Customers From Your Irish Site

You have probably been told that Brexit closed the UK to small Irish sellers. Too much paperwork, too much tax, not worth the bother for a business your size. I hear a version of it most weeks, usually from an owner who switched off UK shipping in their checkout settings back in 2021 and never revisited the decision.

Half of that belief is out of date. The other half is not one problem. It is two, and they have almost nothing in common.

Northern Ireland and Great Britain are separate jobs with separate rules. One of them costs you nothing you are not already doing. The other has a real hurdle, and it sits at a number most owner-operators have never heard of: £135. Treat them as a single lump labelled "the UK" and you will either decline orders you could have accepted, or accept them in a way that leaves your customer holding a bill nobody warned them about.

So let me pull them apart.

Northern Ireland never left, at least where goods are concerned

Start with the half that is simply wrong.

Revenue's position on this could not be much plainer. Northern Ireland, it states, "is subject to the same European Union (EU) VAT rules on goods as EU Member States", and "the supply and movement of goods between Northern Ireland and Ireland in either direction is unchanged" ^[1]. Those movements are still accounted for as intra-Community supplies and acquisitions. Not exports.

Read that again if you have a shipping zone somewhere in your settings that quietly excludes BT postcodes.

A box going from your workbench to a buyer in Newry is not crossing a customs border. There is no export declaration to make. There is no statement on origin to put on the invoice, no EORI number in play, no carrier holding the parcel while it works out what the recipient owes. For a consumer sale it falls under the ordinary EU distance-selling rules, the same ones that govern your sales to Belgium or Portugal. You charge Irish VAT until your total business-to-consumer distance sales across the EU pass €10,000 in a calendar year, at which point Revenue requires you to either register in each destination country or register once for the Union One Stop Shop here at home ^[2].

What that means on a Tuesday morning: your Belfast customer completes checkout exactly the way a customer in the next county does. Same cart, same tax line, same delivery promise, no extra form for either of you.

One honest caveat, because this trips people up. All of the above applies to goods. Services follow a different set of rules entirely, and if what you sell is time rather than product, that is a conversation for your accountant rather than a blog post.

Great Britain is a process, not a wall

Now the half that is real. England, Scotland and Wales genuinely are outside the EU VAT and customs system, and selling there does take setting up. It is not complicated, but it does have a sharp edge, and the edge is at £135.

Consignments of £135 or less: you collect the VAT

For goods that are outside the UK at the point of sale and go directly to a Great Britain customer in a consignment worth £135 or less, HMRC is unambiguous: "The seller must charge and account for VAT at the point of sale, unless the consignment is a business to business sale and the customer has given them their UK VAT registration number" ^[3].

You. Not the border. Not the courier. You, at the moment you take the payment on your own site.

Which raises the obvious question, and I am not going to dress up the answer. To charge UK VAT you need a UK VAT registration, and no turnover threshold protects a small seller here. HMRC's own registration manual states that a business without a UK establishment "is liable to register under Schedule 1A of the VAT Act 1994 if it makes taxable supplies of any value" ^[4]. Any value. Your first £40 order to Manchester puts you in scope on the same footing as your five hundredth.

That is the genuine hurdle in this article, and it is a commercial decision rather than a technical one. A registration plus periodic returns is real ongoing admin. If Great Britain is a market you actually want, that is a modest cost of entry against the revenue it brings. Expecting four orders a year from there? Then it may honestly not be worth it, and I would rather you worked that out now than three months in.

Consignments over £135: the border collects, and someone has to pay

Above the line, the mechanism flips. HMRC applies "normal VAT and customs rules" on importation ^[3], which means the import VAT and any duty fall due when the goods arrive rather than when the order is placed.

Duty is usually the easy part. Under the EU-UK Trade and Cooperation Agreement, goods of EU origin move at a preferential zero tariff, provided you claim it and can prove it. Proof is a statement on origin on your commercial invoice, carrying your exporter reference. Revenue allows unregistered exporters to certify origin for consignments "having a value which is below €6,000", and requires registration on the Registered Exporters System above that ^[5]. For a small maker shipping a few hundred euro at a time, that is a line of text on an invoice, not a compliance project.

Import VAT is where the trouble starts, because it is not really a tax question. It is a customer experience question.

The order that comes back, and the review you cannot answer

Consider a typical case, and this pattern turns up often enough that I could set my watch by it. A Louth workshop building boutique guitar pedals takes an order from a player in Bristol. Nice margin, nice product, well over the £135 line. It ships that afternoon.

Two things then happen that the seller never sees. The carrier works out the import VAT the buyer now owes, then adds its own administration fee on top before it will release the parcel. Neither of those is unfair or unusual, and the same thing happens in reverse on anything arriving here from outside the EU. The buyer, meanwhile, believes they have already paid in full, because the website said nothing to suggest otherwise.

They refuse the parcel. It sits, then it comes home. The seller funds the return leg, refunds the order, and picks up a one-star review that says "hidden charges" in a shop window they cannot edit.

Nothing there was a tax failure. The maths was correct throughout. It was a copy failure, on a delivery page that never named who pays the import charge. Being upfront about what a delivery actually costs is not just good manners either. It is close to the heart of what Irish consumer law already expects you to disclose about delivery charges before the order is placed, and the same instinct serves you well on the far side of the Irish Sea.

There is a straightforward alternative. Ship delivered duty paid, absorb the import charges yourself, and build them into the price. Your British customer then sees one number and pays one number. It costs you margin and it wins you the order, which is usually a trade worth making on anything with a decent unit price.

One market, two entirely separate sets of rules.

Three destinations, three different jobs

The whole thing fits on one screen. Every row below is covered in detail in the sections around it.

Where the parcel is going	VAT you charge at checkout	Customs paperwork	What your site needs
Northern Ireland	Irish VAT, or the destination rate via the One Stop Shop once EU distance sales pass €10,000	None. Treated as an intra-Community supply	Nothing beyond your normal EU setup
Great Britain, consignment £135 or less	UK VAT, charged at the point of sale	Export declaration and a statement on origin	UK VAT registration and a UK tax rate at checkout
Great Britain, consignment over £135	None. Import VAT falls due at the border instead	Export declaration, statement on origin, REX registration above €6,000	A plain statement of who pays the import charges

What your website actually has to do differently

Four changes, and none of them are dramatic.

Separate your shipping zones properly. Northern Ireland belongs with your EU destinations, not with Great Britain. If your store treats "United Kingdom" as one zone, it is applying GB logic to NI orders and quite possibly blocking them outright.

Add a UK tax rate that applies only where it should. It applies to Great Britain, and only to consignments at or under £135. This is the fiddly one, and it is worth verifying in a staging environment before you push anything to production, because a tax rule that misfires on live orders is expensive to unpick afterwards.

Say who pays import charges, in plain words, on the delivery page. One sentence. "Orders to Great Britain over £135 are shipped delivered duty paid, so there is nothing further to pay on arrival" is worth more than any amount of tax configuration.

Put your EORI number and origin statement on the commercial invoice. Get the EORI through Revenue's online service. The statement on origin is boilerplate you write once.

All four of those live in settings you need to be able to reach. That is the practical argument for running your shop on full WordPress rather than a closed builder: tax rates, shipping zones and checkout copy are yours to change at four o'clock on a weekday without raising a support ticket or waiting for a feature to ship. It is also why everything included for €60 a year, with staging and Irish support in the price, matters more for a business selling across a border than for one selling down the road. When you need to test a tax rule against a real checkout, you need somewhere safe to break it first.

Where a closed platform genuinely does this better

Now the honest part, and it cuts against my own argument.

If your Great Britain volume is genuinely tiny, a handful of low-value parcels a year, then listing those items on a large online marketplace is less work than a UK VAT registration. HMRC's rules make the marketplace the liable party for consignments of £135 or less: "Where those goods are sold through an online marketplace, the online marketplace will be liable for the VAT", and the marketplace "must charge and account for VAT at the point of sale" ^[6]. The registration burden moves off you entirely.

That is a real advantage and I will not pretend otherwise. You pay for it in commission, in customer data you never see, and in a relationship that belongs to the platform rather than to you. For a small trickle of GB orders alongside a healthy direct business at home, that trade can be perfectly sensible. Building a market you actually intend to grow is different, because then you are renting a customer base you could own, which is the same calculation that applies to every intermediary between you and the person paying you.

What your website cannot do for you

Your checkout can charge UK VAT correctly on every order. It cannot file the return. The registration, the periodic submissions and the record-keeping stay with you and your accountant, and no plugin changes that.

There is a subtler limit too, and it is worth knowing before it bites. The £135 test applies to the consignment, not the order. HMRC is explicit that the limit "applies to the value of a total consignment that is imported, not the separate value of individual items that are in a consignment". Your website knows what the basket came to. It does not know how many boxes eventually leave your workshop. Split a £200 order into two parcels to protect something fragile and you have created two consignments below the line, with a different VAT treatment from the one your checkout just applied. It is not common, but it is the kind of detail that is much easier to handle deliberately than to explain retrospectively.

Where that leaves you

The market on the other side of the border did not close in 2021. It divided.

Northern Ireland is available to you today, with the checkout you already have, under rules Revenue never changed. If BT postcodes are switched off in your settings, that is a decision worth ten minutes of your afternoon.

Great Britain asks more. It asks for a registration you may not want, a line of copy you have probably never written, and a decision about who absorbs the import charge. Whether that adds up depends entirely on how much of your product you think British buyers want, and you know that number better than anyone.

What is no longer true is that the choice was made for you.

Frequently Asked Questions

Do I have to register for UK VAT to sell to customers in Great Britain?

If you sell goods direct from Ireland to a consumer in Great Britain in a consignment worth £135 or less, HMRC requires you to charge UK VAT at the point of sale, which means holding a UK VAT registration. There is no turnover threshold for a business with no UK establishment: HMRC's registration manual says such a business is liable to register if it makes taxable supplies of any value. Above £135 the VAT is collected at import instead, so the registration question changes shape. Confirm your own position with your accountant before you switch UK shipping on.

Do I need customs paperwork to send goods to Northern Ireland?

No. Revenue states that the supply and movement of goods between Northern Ireland and Ireland in either direction is unchanged, and that Northern Ireland is subject to the same EU VAT rules on goods as EU member states. A parcel sent from here to Newry is not an export. It needs no customs declaration and no statement on origin. This covers goods; services follow different rules.

What does the £135 threshold actually apply to?

The value of the whole consignment that crosses the border, not each individual item. HMRC is explicit that the limit applies to the total consignment being imported rather than the separate value of the items inside it. Two £80 items shipped in one box are a £160 consignment. The same two items sent as two separate parcels are two consignments below the line.

Should I price in euro or pounds for UK customers?

Neither is required, so treat it as a conversion decision rather than a compliance one. A euro price forces a British buyer to work out what the card will actually take, which adds hesitation at the worst possible moment. A pound price removes that. If you do show pounds, hold the rate steady for a reasonable period rather than repricing daily, because a price that moves between the product page and the basket costs you more in trust than the exchange rate costs you in margin.

Who pays the import VAT on a parcel worth more than £135?

Whoever your shipping terms say. Ship delivered duty paid and you pay the import charges yourself, then build them into your price. The alternative, delivered at place, puts them on the buyer when the parcel arrives, along with whatever handling fee the carrier adds before it hands the parcel over. Both are legitimate choices. What is not legitimate is failing to say which one you have made, because the buyer finds out at the door.

Do I need an EORI number to sell to Great Britain?

Yes. The EORI number is the customs registration number Revenue issues through its online service, and it identifies you on every export declaration. You also need it on any statement on origin used to claim the zero tariff under the EU-UK Trade and Cooperation Agreement. For consignments below €6,000 you can certify origin without registering on the Registered Exporters System; above that value, Revenue requires REX registration.