It is necessary to collect and pay VAT to the UK on the sale of digital items. All business-to-consumer (B2C) sales into the UK, both physical and digital, are subject to VAT regardless of value.
This guide will discuss the most important factors to consider when selling into the UK, what qualifies as a digital service, examples of these services, combined digital and physical sales, and information on VAT registration. Our UK VAT guide covers more details on the entire scheme, including VAT registration and remittance.
The terms digital service, digital product, online service, and e-service are used interchangeably in this document.
Digital services include telecommunications, broadcasting, and electronic services (TBE), or services that are supplied electronically (ESS) (downloaded, emailed, etc.) as opposed to being physically shipped.
If an item is stored digitally, supplied/delivered electronically with minimal human involvement, and used in an electronic format, it is considered a digital product or service. These are products that the customer receives via email, by downloading from the internet, or through logging into a website, i.e. software, digital audio, video, and ebook files.
Gift card purchases online are not considered digital products.
Example 1: A PDF that you purchase and download from the Internet without human involvement is considered an electronically supplied service.
Example 2: A PDF that you purchase online and receive in the form of an email attachment from the online retailer is not considered an electronically supplied service.
Source: UK VAT rules for digital services
|Service||E-service (Yes/No)||Electronically supplied (Yes/No)||Subject to VAT (Yes/No)|
|PDF document manually emailed by seller||Yes||No||No|
|PDF document automatically emailed by seller’s system||Yes||Yes||Yes|
|PDF document automatically downloaded from site||Yes||Yes||Yes|
|Stock photographs available for automatic download||Yes||Yes||Yes|
|Online streaming services and music, films, and games available for download||Yes||Yes||Yes|
|Online course consisting of pre-recorded videos and downloadable PDFs (with no live instructor involved)||Yes||Yes||Yes|
|Online course consisting of pre-recorded videos and downloadable PDFs plus support from a live instructor||Yes||No||No|
|Individually commissioned content sent in digital form, for example, photographs, reports, medical results||Yes||No||No|
|Link to online content or download sent by manual email||Yes||Yes||Yes|
Physical products and digital products can be bundled together on one invoice for tax purposes or provided as separate sales with separate invoices. Since every digital or physical sale is taxed regardless of the value, it no longer makes sense to split the invoices.
Examples of bundled supplies:
The two most important key factors to remember about UK VAT (for physical **and **digital sales into the UK) are as follows:
For B2C digital sales into the UK, the most important factors to consider are as follows:
The location of your customer
Your business' location
Whether your customer is a business or an individual consumer
Whether your online store is independent or part of an online marketplace
See our UK VAT guide for details on VAT collection, registration, and remittance to HMRC.
If your business sells goods under £135 to UK VAT-registered businesses, the responsibility to remit tax falls to the customer; however, the customer’s VAT number must be included on the invoice, along with a note making it clear that the customer’s business is responsible for VAT, i.e. “reverse charge: customer to account for VAT to HMRC.”
Failure to register and pay VAT in the UK is tax evasion.
The UK is committed to keeping the playing field even between sellers at home and abroad and has enacted legislation that allows HMRC to hold sellers liable for unpaid VAT.
See Zonospolicies and agreements.
UK VAT on digital services