Selling printables to EU customers: the VAT is due there

A printable planner sold as a download to a customer in Dublin carries Irish VAT. Sell the same file to Berlin and it carries German VAT. HMRC's guidance on digital services sold to private consumers is short on this point: "The place of supply will be where the consumer is located." It names no sales threshold below which a UK business can ignore it.

Printable 2027 planners and calendars sell from now until January, and for sellers already registered in the EU, the return for October to December falls due on 31 January 2027.

What counts as a digital service

The rule covers services delivered over the internet "where there's minimal or no human intervention". HMRC's examples include "photos, screensavers, e-books and other digitised documents" and software. A PDF planner that downloads automatically after payment is squarely inside it. A course with a live tutor is outside it, and so is anything you post.

Etsy or your own store

Where you sell decides who deals with the VAT. HMRC's guidance says that when a digital service is sold through a third-party platform, "the digital platform is responsible for accounting for VAT on the supply instead of you", where the platform sets the general terms and conditions, authorises the payment or handles delivery. It adds that "the vast majority of digital platforms will be liable".

A store of your own is the other case. On a Shopify or WooCommerce site you set the terms of sale and the customer buys from you, so you are the supplier. The guidance is explicit that a business whose only role is processing the payment is not treated as a digital platform. The VAT on an EU customer's download from your store is yours to account for.

Register once, in one country

HMRC gives a UK business two choices: register for VAT in every EU country where you have consumers, or register for the EU's single scheme in one member state. The European Commission's One Stop Shop registration page calls the second the non-Union scheme. It is for businesses not established in the EU that supply services to consumers there, and you can choose any member state to register in.

The timing rules are strict. Registration normally takes effect from the first day of the next calendar quarter. You can use the scheme from your very first sale instead, but only if you tell your chosen country by the tenth day of the month after that sale. Miss that and, until the registration starts, you are back to registering in each country where you sold.

A quarter in the life of a planner shop

Illustration, not a real client: a UK seller runs a Shopify store selling printable planners. Her first EU sale is to a customer in France on 18 July 2026. She registers for the non-Union scheme in Ireland on 6 August, inside the ten-day window, so the scheme covers her from 18 July. Between July and September she sells planners to consumers in France, Germany, Ireland and the Netherlands, each sale charged at that country's VAT rate.

The Commission's guidance on declaring and paying sets the rest. The return is quarterly and due "by the end of the month following the tax period", so her July to September return was due on 31 October 2026, with payment by the same date. October to December, her busiest quarter, is due 31 January 2027, the same day as her UK Self Assessment. And in a quarter with no EU sales at all, she still files, because the Commission says "a 'nil return' is to be submitted".

Before 31 January

Look at your store's order export from July onwards and filter by billing country. If every EU sale went through Etsy or another marketplace that handled the VAT, there may be nothing for you to do. If any went through your own checkout, you need a registration that covers them, and a checkout that charges each buyer the rate of their own country.

Our guide to VAT on digital downloads from your own store walks through the UK side as well, and our page for Shopify sellers looking for an accountant covers cross-border VAT more widely. Set a reminder for the last day of January, April, July and October now. Those four dates do not move.

About the author

Harvey Dhillon is Founder and CEO of Zmartly, a UK accountancy firm for ecommerce sellers. He grew up in West London and began his career in investment banking finance at Barclays, before going full-time on Zmartly in 2020. He is a Chartered Management Accountant (ACMA, CGMA).

Featured photo by Kelly Sikkema on Unsplash.