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VAT implications of cross-border trade of services

In this article we summarise the VAT implications of cross-border trade of services.

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Contents

Introduction
Trade between Ireland and Northern Ireland
Further Information

Introduction

It is essential that traders understand and apply the relevant VAT rules correctly. There are a number of VAT considerations which businesses that are centred around the provision of services need to take into account. Northern Ireland remains aligned to many EU VAT rules on goods. Northern Ireland is not aligned to EU VAT rules on services.

Trade between Ireland and Northern Ireland 

Business to Business: Place of supply is where the customer belongs.

Where services are received by NI traders from EU businesses, the NI business should self-account for VAT.

Where services are provided to EU VAT registered businesses by NI traders, the EU business should self-account for VAT.

B2B supplies of services to EU residents are taxed under the reverse charge, meaning that the customer accounts for VAT in the country in which it is established. That means that a UK business receiving a supply from a European business account for UK VAT on that supply. Conversely a UK service provided to a French business is outside the scope of UK VAT, but the French company accounts for French VAT on the service.

Note, the rules outlined above apply to general rule services. Special VAT rules apply to a variety of different services. We have listed below a number of the most common services that attract "special" VAT treatment:

  • Services relating to a specific piece of land / a specific building
  • B2C passenger transport services
  • The letting on hire of goods (including means of transport)
  • Restaurant and catering services
  • Radio, television & telecommunications services
  • Electronically supplied services (digital services)
  • Admission to events (e.g., cultural, educational and entertainment activities)
  • Freight transport
  • Services supplied where performed (e.g., repair work carried out on goods)
  • Intermediary/ agency services
  • Financial services
  • B2C services of a professional / technical / financial / intellectual nature (e.g., consultancy / legal / engineering / accountancy services).

Business to Consumer: Place of supply is where the supplier belongs.

General rule services supplied to NI private customers by suppliers based in Ireland should continue to be subject to Irish VAT.

The general rule services supplied to EU private customers by UK suppliers should continue to be subject to UK VAT.

As noted in the B2B information above, specific services often attract specific VAT rules. From a B2C perspective, the following key rules are particularly important:

  • B2C services of a professional, technical, financial, intellectual, or other intangible nature supplied by a UK/EU business to non-business customers outside of the jurisdiction in which the supplier is established (i.e., outside the UK/EU). This includes the services of advertisers / consultants / engineers / lawyers / accountants / financial services / supply of staff amongst other supplies. These services are deemed to be supplied where the customer belongs. As such, where such services are supplied by a UK supplier to a non-business customer based in the EU, the services are outside the scope of UK VAT. Similarly, B2C services of this nature provided from suppliers based in Ireland - NI/GB based B2C customers will be outside the scope of Irish VAT. This is different to the position pre-Brexit. The Irish supplier will have a responsibility to register for UK VAT and account for the VAT as a zero threshold applies for non-established traders. The reverse situation (GB/NI supplier to B2C ROI B2C customer) applies to certain types of services. Further specialised advice is required here. 
  • B2C supplies of digital services - where suppliers provide electronically supplied services, the place of supply (i.e., the place where a VAT liability is likely to arise) will be the place where the customer is located.  

                        Summary of the place of supply of services rules in Ireland 

 Country of establishment of supplier   Country in which customer established   Status of customer   Place of supply   Person liable to account
for Irish VAT 
 Ireland  Ireland  Business or Private  Ireland

Supplier
 Ireland   Other EU State   Business   Other EU State   No Irish VAT 
 Ireland   Other EU State   Private   Ireland   Supplier 
 Ireland  Outside EU  Business   Outside EU   No Irish VAT 
 Ireland  Outside EU  Private   Depends on nature of the Service   Supplier (if VAT occurs) 
 Other EU State  Ireland  Business   Ireland   Business customer 
 Other EU State  Ireland

Private

  Other EU State   No Irish VAT 
 Outside EU  Ireland  Business   Ireland   Business customer 
Outside EU Ireland  Private  Depends on nature of the Service  Depends on nature of the service - if taxable in the State - the supplier 

 
 
For VAT on services information for Ireland, Northern Ireland and GB please see VAT Implications of Services - Ireland, Northern Ireland and GB
 

Note: Professional VAT advice should be sought if traders are unsure as to the appropriate VAT treatment of the supply of specific services. 

Further information

GOV.UK: Guidance on Place of supply of services (VAT Notice 741A)

Revenue.ie: Guidance on VAT on services

Do you need further help or advice?

Article reviewed: July 2025