Brexit, Overseas Online Retailers & VAT- a disaster waiting to happen

With Brexit looming large the government needs to urgently put a plan into place and examine the effects that Brexit will have on Online Marketplaces, Overseas Retailers, Global Fulfilment, Distant Selling, Subsidised Chinese post, LVCR Abuse, VAT & the Split Payment model.

We propose that the government must:

  • Introduce VAT Split Payment model for ALL UK & NON UK online retailers.
  • Introduce a destination based VAT system for cross-border e-commerce, as proposed by the EU.
  • Scrap LVCR.
  • Stop subsidising Chinese post via UPU terminal dues.

The benefits are:

  • VAT income will sky rocket.
  • VAT will be collected at point of sales using “Split payments” by the Online Marketplaces such as Amazon & eBay no matter where the stock or seller is located.
  • LVRC abuse and the unfair 20% price advantage from distant sold low value goods will end. This will include all EU companies who will be able to distant seller into UK after Brexit.
  • It will level the playing field for UK online retailers competing on Online Marketplaces with Overseas Retailers who illegally don’t charge VAT.
  • Under valuations of small packages entering the UK will end.
  • Small packages will be able to move more freely through the new Customs Declaration Service (CDS).
  • Chinese retailers will not be able to benefit from artificially low postages rates that are causing a huge market distortion in pricing of physical mail order goods.
  • UK Online retailers will flourish as Chinese sellers pull out of the UK market as they will no longer compete with the illegal 20% price advantage.

Post Brexit VAT disaster

Here is the scenario of what will happen if we leave the EU and keep our current out of date VAT System & LVCR.

  • Every country in the world, including the EU will be able to distant sell into the UK with the customer paying the VAT & Duty.
  • The postman will become the VAT collector for every distant sold package sold into UK.
  • Prices for all non UK sellers, with stock located outside the UK on will be displayed without VAT at 20% cheaper.
  • All goods under £15 from non UK retailers will be sold VAT free and have a 20% price advantage.
  • Non UK sellers will move their stock currently in Amazon UK to Amazon warehouses in the EU and have their UK VAT Free orders fulfilled by Amazon in the EU.
  • The new Customs Declaration Service (CDS) will have to cope with an additional unprecedented 90 million to 390 million declarations a year by 2019
  • Chinese owned fulfilment houses in Calais will flourish with Overseas Sellers being able to take orders, drive them 32 miles through the channel tunnel and dispatch them into the UK Royal Mail service on the same day.
  • UK Retailers will have to register for VAT in the EU if they want to continue to cross border trade with EU customers.
  • UK retailers will no longer be able to compete on price in the UK and will be killed off
  • UK retailers will move offshore to Calais to be able to compete in the UK.
  • We will see the same LVRC abuse that occurred in the Channel Islands but this time on a global scale.
  • Chinese sellers will be able to sell VAT Free goods dispatched from China cheaper than the stamp it would cost to send the goods from the UK.

Destination based VAT system

The EU understands that the current 21 year old VAT system is archaic and not fit for purpose with the rapid expansion and globalisation of eCommerce Cross border trading.

The EU is introducing a destination based VAT system for physical mail order goods, having already successfully implemented the system with downloadable goods. The EU estimates that as much as EUR 25 billion in trade (25% of total cross-border B2C sales of goods) is non-compliant.

The new EU VAT Regulations extends to all overseas online retailers distant selling from outside the EU. This means ALL Chinese online retailers who distant sell into the EU will have to register for VAT and pay VAT in the EU. Currently a Chinese Seller can distant sell into the EU without charging VAT.  The VAT & Duty is collected from the customers who purchased the goods.  A recent study showed only 35% of VAT is collected via Postal operators on eCommerce Imports.

The new Customs Declaration Service (CDS) will not be able to cope with the additional unprecedented 90 million to 390 million declarations a year, as all EU goods will be classed in the same as way as imports and exports from third countries.

The old distant selling system has been open to a mass of abuse with Overseas miss-declaring the goods as gifts and valuing them as little as 1% of their true value in order to gain LVCR on the goods so no VAT or Duty is collected at all.

If the UK government adopts a destination based VAT system in conjunction with introducing the VAT spilt payment system it would help put an end to Online VAT Fraud by UK & Overseas Sellers. It would also put an end to the difficulty of collecting the correct amount of VAT due from Distant Sellers.

Scrap LVCR – Low Value Consignment Relief

The EU has scrapped LVCR due the abuse and market distortion it is causing.

LVCR is a relief from VAT on goods imported into the EU with a value of £15 or less. Goods dispatched by Overseas Online Retailers from outside the EU to customers in the UK can be sold VAT free as long as they are valued under £15.

Overseas Online Retailers are abusing LVCR by under declaring the value of the goods so no VAT or Duty is paid.  We have evidence of goods being declared at 1% of true value by Overseas Online Retailers on Amazon and eBay. The scale of this fraud is huge; there are 1000’s of Overseas Online Retailers on Amazon and eBay distant selling into the UK.

LVCR is already causing a huge market distortion on price and competitiveness against UK retailers competing with overseas retailers who have a completely legal 20% price advantage on goods they sell to UK customers on UK Online Marketplaces.

If the UK government don’t scrap LVCR post Brexit, every European & overseas business will have a 20% price advantage right on our door step. This will be the Channels Island VAT Loophole all over again, this time on a global scale. At the time HMRC refused to close down the LVCR VAT abuse seen in the Channel Island and it took a High Court Ruling to get it closed down.

By scrapping LVCR and in conjunction with introducing the VAT split payment system, low value goods will remove the abuse and market distortion it causes. It will also remove the burden LVCR causes to UK Customs and Customs Declaration Service.

Stop subsidising Chinese post via UPU terminal dues.

Chinese sellers are being offered hugely subsidised postal services known as “Terminal Dues” by the United Nation’s Universal Postal Union (UPU) allowing Chinese retailers to sell goods including postage from China to the UK for less than the stamp would cost a UK retailer to send the same item from the UK.

For instance a set of football shin pads on eBay can be purchased for as little as £1.50 including express delivery from China to the UK. They will also be VAT Free under LVCR.

To send the same football shin pads from the UK would cost £2.58 for a Royal Mail 2nd Class package stamp.  If a UK retailer sold the shin pads for £1+VAT plus delivery the total cost would be £3.78. That is more than 2.5 times the price the Chinese seller is able to sell the same product to the same UK consumer.

When the Chinese packaging enters the mail system in the UK it is handled like any other package and it is costing the UK Postal Service of tens of £millions each year, which translates into costs for U.K consumers.

It not only disadvantages UK retailers in their competition with Chinese Retailers, it costs the U.K government millions of pounds in lost customs revenue.

The UK government must stop the United Nation’s Universal Postal Union (UPU) “Terminal Dues” subsides for Chinese Online Retailers.


If the government took on board all our recommendations it would:

  • Level the playing field for UK Online Retailers
  • Increase VAT revenues
  • Decrease the burden on Customs and Excise for distant sold goods
  • Decrease the burden of the Postman collecting VAT
  • Remove market distortion caused by LVCR and Universal Postal Union Subsidises

If the government introduced VAT ‘split payment’ model without implementing our recommendations the only VAT it would collect is from UK retailers because all non UK retailers will have moved 20.7 miles off shore and would distant sell from outside the UK.

In our opinion it would be foolish if the government did anything else other than implement our recommendations.


VAT: ‘split payment’ model for online retailers:

EU Digital Single Market Modernising: VAT Cross Border eCommerce:

Destination Base VAT Principle Explain by EU

Destination Based VAT Mini One Stop Shop (VAT MOSS) – Downloadable Goods

Only 35% of VAT in collected via Postal operators on eCommerce Imports:

The new Customs Declaration Service (CDS) will not be able to cope:£70m-customs-computers-unable-cope-brexit-says-official

High Court Decision Confirms End of Channel Islands LVCR Abuse and Clarifies State Power to Exclude Mail Order Goods from LVCR:

Retailers Against VAT Abuse Schemes – RAVAS -Watching the Watchmen:

Crisis in The Mail: Fixing A Broken International Package System – Analysis:

Stop Subsidizing Foreign Postal Systems, for Economic Fairness and National Security:

The United Nations is helping subsidize Chinese shipping. Here’s how:

Your Chance to Weigh in on Low Postal Rates for China Sellers:

Universal Postal Union (UPU):

Copy of HMRC Notice to VAT Evading sellers taken from Amazon forum

Here is a copy of HMRC Notice to VAT evading sellers taken from Amazon forum :

Dear Sir/Madam,

New measures were introduced by HMRC for some businesses established overseas that are required to be registered for VAT in the UK. With these new measures, we may:

· direct a business to appoint a VAT representative in the UK
· require a business to provide a security to HMRC
· rule that an online marketplace provider and/or a UK VAT representative are jointly and severally liable, together with the business, for any UK VAT debts that become due.

You can find more information on the New Measures by visiting and searching for ‘overseas businesses using an online marketplace to sell goods in the UK’.

I now require you to read the attached letter and register for UK VAT. Can you please notify me by 16 February that this has been done and provide me with a copy of the reference

I also wish to review the following business records

· Annual accounts and bank statements
· Books of account: sales and purchase daybooks, cash books, petty cash books and ledgers
· sales and purchase invoices
· A brief overview of the business and its main activities to include when the business commenced and when it started to sell goods within the UK market.
· Import Records
· Completion and return of the attached Import Questionnaire

Should you wish to discuss this with a member of the online selling complaince team, as postal communications can take some time, you may prefer to correspond by email. Of course, there is no problem if you prefer to correspond by post in relation to this matter and I will assume this to be the case if you do not respond to this email. However, if you would prefer to correspond by email, HM Revenue & Customs requires a director of the company to confirm in writing that they understand accept the risks involved in using email. It is important that you have assessed the risks of using email to send information or to receive it. If you use email to send HMRC information, you do so at your own risk.

HM Revenue & Customs takes the security of personal information very seriously and recognises that it has privileged access to data, which we endeavour to protect. Therefore, in order for us to respond to any queries by e-mail, we need to obtain written confirmation that the director.
Has no objections to corresponding by email (if this includes agents or representatives – please specify), and
Understands and accepts the risks associated with e-mail, and
Has no objections to us sending information concerning the details of the company

HM Revenue & Customs will de-sensitise information wherever possible (e.g. quoting only part of unique reference numbers) and we are happy to discuss how you may do the same but still provide the information we need. However, if you would prefer us not to respond to your enquiries by email (e.g. because other people have access to your email account) we are happy to respond by post. For further information see: HMRC Privacy Policy

Therefore, if you accept the security risk and wish to correspond by email, please reply to this email advising that, although you are aware that email correspondence is not secure, you wish to use it. That will then give me authorisation to provide full details of my enquiry by email. Please note the email capacity has been limited to 8mb. Therefore, if the information to be supplied is more than this, separate emails, each less than 8mb, will be required.

General information regarding UK VAT can be found on our website, at

Kind regards

On Line Selling Compliance Team

Amazon Notice to VAT Evading Sellers

jailHMRC & Amazon issue “GET OUT JAIL FREE CARDS” to VAT Evading Overseas Online Retailers. The card allow them to:

  1. Evade all unpaid VAT.
  2. Continue trading for 30 days.
  3. Keep their stock.
  4. Withdraw all their funds.
  5. Keep their highly ranked listings.
  6. Relist their old stock on their highly ranked listings under a new company.

Well done HMRC !*&!$$$

We have seen a copy of the notice Amazon are sending to VAT Evading Sellers.  Amazon sends the notice once they receive a liability notice from HMRC.

It is completely beyond belief that HMRC are not seizing stock, freezing assets and permanently removing the sellers listing from the Amazon catalogue.

Doesn’t HMRC realise that these sellers will simply remove their stock, setup a new company and send the stock back into Amazon and sell it on their old highly ranked listings. And avoid paying any of the unpaid VAT from their old company.

What is sort of deterrent is this? What on earth is going through HMRC’s mind!!?

We can’t believe the complete incompetence that HMRC are still showing in tackling online VAT Fraud.

It makes our blood boil.

Here is the Amazon notice:


We received a notice from the UK tax authority, Her Majesty’s Revenue and Customs (HMRC), indicating that you do not currently meet VAT requirements in the UK.

Sellers on Amazon must comply with all applicable laws and regulations. As a result, you may no longer sell on and you are no longer allowed to use our Fulfilment by Amazon (FBA) service in connection with

Please ship any open orders and submit a request to remove any FBA inventory from our fulfilment centers in the UK (

If you do not submit this request within the next 30 days, we may dispose of your inventory.

Additionally, you may no longer offer to ship items into the UK on any of Amazon’s European marketplaces.

You may also no longer use our FBA service to ship items into the UK. Your shipping options have been restricted accordingly.

If you have funds in your Selling on Amazon payment account, they will be available after any amounts for A-to-z claimsor chargebacks on your orders have been deducted. This usually takes about 90 days, but funds may be held longer by Amazon Payments Europe S.C.A.

Please contact HMRC at to resolve your VAT status.

Once HMRC informs us that their notice has been withdrawn, we may allow you to sell on again.

Please let us know when you resolved your VAT status with HMRC by emailing

To learn more about UK VAT obligations for overseas sellers, visit the UK Government website (

For information on tax advisory firms with discounted rates for Amazon sellers, visit our VAT Resources help page (


Amazon Services Europe

Stop subsidising Chinese Retailers post via United Nations Universal Postal Union (UPU) terminal dues.

Chinese Retailer are being offered hugely subsidised postal services known as “Terminal Dues” by the United Nation’s Universal Postal Union (UPU) allowing them to sell goods including postage from China to the UK for less than the stamp would cost a UK retailer to send the same item from the UK to the same customer.

United Nations UPU class China, the second biggest economy in the world, as a Category 3 Economy along side Gabon. This entitles Chinese online retailers huge international postal discounts. Packages can be sent to the UK for less than a penny. And it’s the UK mail service and the cost of our stamps that picks up the tab.

Amazon and eBay have made it extremely easy for Chinese Retailers to sell directly to UK consumers on their platforms. Chinese Retailers can now offer 7 day delivery times from China. Chinese retailers now account for 25% of all the retailers on these platforms. They are now taking the lion share of sales, undercutting UK retailers by as much as 90%. British retailers don’t stand a chance.

In 2013 Chinese online sales reached $314 billion, or 35 percent of all world e-commerce sales (by comparison, U.S. online sales were $255 billion). Senator Bill Cassidy recently moved to close UN Terminal Dues subsided post system that helps Chinese Sellers undercut USA Sellers on costing the US Mail service $135 million in 2016.

The $1 per Kilo Bulk Rate Loophole

The United National UPU subsidises allows Chinese Retailers to mail goods in bulk on a per kilo rate and not a per items rate that UK Retailer are charged. Chinese are currently being charged from $1 per kg for bulk post from China to USA.

A small letter with small earrings in weighs around 5 grams. This mean 200 letters with earrings in will cost just $1 or $0.005 per item for a Chinese Retailer to send from China. It would cost a UK Retailer £0.58 per letter or £116.00 for all 200 items to send them within the UK.

When the Chinese packaging enters the UK mail system it is handled by Royal Mail like any other UK package and it is costing the UK Postal Service tens of £millions each year, which translates into higher stamp costs for U.K consumers.

This not only disadvantages UK retailers in their competition with Chinese Retailers, it costs the U.K government millions of pounds in lost customs revenue.

United Nations UPU subsides Killing British online and high street retailers

UK Retailers simply can’t compete with Chinese Retailers selling like for like products at a faction of the cost they can sell them. It’s putting us out of business and the government is completely obliviously to the damage the United Nations UPU Royal Mail subsides are having with British online and high street retailers.

The government needs to wake up to what is going on and the harm it is causing our country. This out-dated United Nation’s Universal Postal Union (UPU) “Terminal Dues” policy which subsidises mail from China – the worlds second largest economy – needs to be stopped urgently by the UK government.

Questions the UK government needs to consider:

1) Does subsidised Chinese Post distort the market and put UK retailers out of business?
2) Does distant selling into UK using LVCR so no VAT and Duty is paid distort the market and put UK retailers out of business?
3) Why are we funding & helping Chinese Online retailer to put UK retailers out of business?
5) How much are Chinese Retailers being charge by United Nations UPU per kilo to mail letters & goods from China to UK?

Example Products:

Below are examples of products on Amazon UK dispatched from China by Chinese sellers who take advantage of United Nations Universal Postal Union terminal dues subsidised post. All items are also sold VAT & Duty Free as they are exempted by LVCR – Low Value Consignment Relief.

1) Pack of 12 Plain White Unbranded Table Tennis balls only 0.32p including delivery from China. Cost of stamp for UK seller to send from UK is £2.85. Tennis anyone?

2) Makeup Brush only £0.11 including delivery from China. No 1 best seller on Amazon UK. Cost of stamp for UK seller to send from UK is 79p. That’s got to raise a few eyebrows with UK retailers!!

3) Union Jack Flag – only £1.19 including delivery from China. Number 1 best seller on Amazon. Cost of stamp for UK seller to send from UK is £1.26. Rule Britannia!!

4) Poop Scoop – only £0.23 including delivery from China. Cost of stamp for UK seller to send from UK is £2.85. UK Retailers are going to need a lot of these to get them out of the hole the UN has created them.

5) Travel Plug – only £0.97 including delivery from China. Cost of stamp for UK seller to send from UK is £2.85. EU Safety Standards not included.

6) Sterling Silver Amethyst Purple Heart Crystal Pendant Necklace – only 15p including delivery from China. Cost of stamp for UK seller to send from UK is 79p. A nice present for your loved one. Can’t go wrong here.


1) Universal Postal Union (UPU):

2) In 2012, terminal dues for transit from China to the USA was 0.635 SDR/kg, or about 1 USD/kg.

3) The Times: Chinese retailers are being secretly subsidised by British consumers to send millions of cheap online products around the UK for a fraction of the cost of a postage stamp.

4) Daily Mail: British retailers are furious as Chinese firms ‘use loophole to let them ship goods within the UK for fraction of the cost of a postage stamp’

5) Senator Bill Cassidy moves to close UN Terminal Dues subsided post system that helps Chinese Sellers undercut USA Sellers on & cost the US Mail service $135 million in 2016

6) Canada Post phasing out controversial shipping discount for Chinese goods

7) Swedish Post introduce handling fees & VAT on goods posted from (China) third countries from 1st March 2018

8) As U.S. Postage Rates Continue To Rise, The USPS Gives The Chinese A ‘Free Ride’


9) Crisis in The Mail: Fixing A Broken International Package System – Analysis:

10) Stop Subsidising Foreign Postal Systems, for Economic Fairness and National Security:

11) The United Nations is helping subsidise Chinese shipping. Here’s how:

12) U.S. Government Accountability – Information on Changes and Alternatives to the Terminal Dues System

13) 25% of European Amazon marketplace sellers are based in China

13) Royal Mail 2nd Class Stamp Prices

14) Royal Mail 1st Class Stamp Prices

HMRC handed out 7,185 VAT numbers to Overseas Online retailers!!

HMRC have just released a press statement “HMRC tackles online VAT fraud in time for Christmas. They have handed out 7,185 VAT numbers to Overseas Online retailers in the last year, that’s a tenfold increase in last year’s figures of 695 due to their crackdown of Online VAT Fraud.

However reading between the lines is seems to be desperate attempt by HMRC to get some positive PR and be seen doing something positive in tackling the online VAT fraud they have ignored for the past ten years. The press release simply proves Online VAT fraud is enormous with 7,185 previously unregistered overseas retailers deciding to register for VAT.

It’s worth noting our comments in FT & The Guardian on the HMRC news:

The Guardian – MPs poised to investigate VAT fraud on Amazon and eBay
The Financial Times – Online sales clampdown nets VAT registrations

Lets hope HMRC’s next press release is more news worthy such as; “HMRC close down 7,185 oversea’s online VAT Evading retailers on eBay & Amazon” !!

HMRC have some serious questions to answer;

1) How much undeclared VAT has HMRC recovered from these previously unregistered online retailers?

2) How many of these retailers have declared on their VAT registration forms that they have made no previous undeclared sales?

3) How many of these retailers have HMRC asked to appoint a VAT representative or provide a financial guarantee?

4) How much VAT in now being collected from these previously unregistered retailers?

5) How many Joint and Several Liability notices have been issued to eBay & Amazon for non VAT compliant online retailers?

6) How will HMRC monitor these retailers VAT Returns are true and correct?

One must ask themselves is HMRC handing out VAT numbers without any due diligence or investigation into the retailers previous online trading history?

Great PR stunt HMRC – doesn’t wash with us!

Amazon launches new VAT Compliance Tools for VAT Evading Sellers

Amazon UK have now taken measures to help VAT evading sellers understand what VAT compliance is and whether they need to register for VAT.

They have teamed up with KPMG who have provided an online “VAT registration litmus test“.

We tested the tool and there seems to be some flaws in it. It doesn’t work for NON EU companies (Chinese) with EU stock as it doesn’t ask where your business is located. It also says that you need to hit the VAT threshold before registering for VAT. There is no VAT threshold for NON EU companies. We find the tool completely confusing to use with a very badly designed results page. Hope KPMG are better accountants than web developers.

Perhaps they should think about renaming it from “VAT registration litmus test” to “VAT registration ambiguity test”!!

We launched our own simple test “Am I committing VAT Fraud in the UK?” several years ago. OK we haven’t spent much on it but it does work for NON EU companies. It’s not rocket science!!

We are very sceptical about the reason why Amazon are now doing this. It’s certainly not because they have a moral conscience for being part of the £7.5billion hole they have caused to the UK economy and online businesses. Amazon are only doing this to protect their own revenues and shareholders.

Is Amazon’s time is numbered? Is the noose tighten around their necks for being part of a fraudulent supply chain? They know the main bulk of their European fulfilment operation is built around dispatching goods for Chinese VAT evaders. Amazon’s bottom line is going to take a major hit once the VAT evaders are shutdown.

The only reason why Amazon have been able to get away with it for so long is because of HMRC’s complete incompetence in shutting this fraud down. We have seen a whole host of new policies and announcements but have seen very little action in actually shutting down these VAT evaders on Amazon & eBay. HMRC needs to up their game.

Lets hope the EU & UK take Amazon to court and make them liable.

Here is the headline that appeared on Amazon Seller central:

New Tool and Resources Page for VAT Information

23 Nov 2016
Selling your products on the UK and other Amazon European Marketplaces can help you grow your business. To set up your business for international success, one of the important considerations to keep in mind is how you manage Value Added Tax (VAT). If you’re selling into an EU country from outside EU, it’s essential to be aware of any potential VAT requirements.

Take the newly launched Litmus Test to assess your VAT registration needs

To make compliance easier, it’s important to know which specific countries you’re selling into, and to have an understanding of their requirements in those countries. The VAT rules for every EU country are different. But there are some basic factors that will help determine whether you will have to register for VAT within a certain country, including:

• Where you are based/established
• From where you ship goods into this country
• Where your customers are based
• Whether your customers are consumers or businesses
• The level of your sales

You have a specific example in mind and don’t know if you need to VAT register or not? Take Litmus test and find out now (

Visit our new VAT resources page to learn more about VAT compliance requirements

There are some precise steps you’ll need to take to register and file your VAT returns. As an example, here’s what someone selling into the United Kingdom would need to do to be compliant:

• Register for VAT
• Charge the correct amount of VAT to UK customers at checkout and issue correct invoices where required
• Submit your VAT returns by the due date
• Pay any VAT due to HMRC
• Keep proper VAT records

This is just an example of the steps required in one country — while the general process is similar elsewhere, you’ll need to have an understanding of each country’s requirements before you start selling to customers located there (and charging them VAT). Visit our VAT resources page ( to learn more about VAT compliance requirements in the UK.

Autumn statement tackles VAT Fraud via Fulfilment Houses

The government has just announced in the Autumn statement the Implementation of the Fulfilment House Due Diligence Scheme in 2018 to tackle VAT fraud by overseas businesses selling goods via online marketplaces.

Lets hope Amazon Fulfilment will be held liable of all VAT Fraud being committed from its warehouses. Amazon “Should have known or would have known!!!”

In addition to that the government have given Customs and excise officers new powers to inspect goods.

Full statement here:

4.3 Implementation of the Fulfilment House Due Diligence Scheme

As announced at Budget 2016 and following a consultation on the scope and design of the scheme, the government will legislate in Finance Bill 2017 to introduce a new Fulfilment House Due Diligence Scheme in 2018. This will ensure that fulfilment houses play their part in tackling VAT abuse by some overseas businesses selling goods via online marketplaces. The scheme will open for registration in April 2018.

6. Avoidance and evasion

6.2 A penalty for participating in VAT fraud

As announced at Budget 2016 and following consultation, the government will legislate in Finance Bill 2017 to introduce a new and more effective penalty for participating in VAT fraud. It will be applied to businesses and company officers when they knew or should have known that their transactions were connected with VAT fraud. The penalty will improve the application of penalties to those facilitating orchestrated VAT fraud. The new penalty will be a fixed rate penalty of 30% for participants in VAT fraud. This will be implemented following Royal Assent of the Finance Bill 2017.

6.3 Power to examine and take account of goods at any place

The government will introduce legislation in Finance Bill 2017 to extend the current customs and excise powers of inspection. This will amend the Customs and Excise Management Act 1979 and enable officers to examine goods away from approved premises such as airports and ports, to search goods liable for forfeiture and open or unpack any container. This will take effect from Royal Assent of the Finance Bill 2017.

Amazon UK bans incentivised reviews

Amazon have just updated their Review policy on Amazon UK & EU. No more free giveaways in exchange for a review.

Chinese  Seller using this technique to boost their product ranking and sales.  Seem’s like Amazon are taking review manipulation seriously.  Shame they don’t take VAT Fraud seriously.

Since Amazon’s announcement yesterday it seems that the mass of Amazon Review Facebook groups have already found a way round the new rule:


Here is the headline in Amazon Seller Central:

Additional information about incentivised review policy
22 Nov 2016

Amazon recently updated its policies to prohibit incentivised reviews, including those posted in exchange for a free or discounted copy of the product.

We consider a review to be incentivised if you have influenced or can influence the review directly or indirectly, including by monitoring whether a review is written and providing or withholding any future benefit based on whether a review is written or the content of the review. Below are a few examples where a review is considered incentivised and is not permitted:

  • You provide a free or discounted product, gift card, discount, cash payment or other compensation in exchange for the review.
  • You provide or withhold free or discounted products or other benefits in the future based on whether the buyer writes a review.
  • You use a review service where reviewers’ continued membership depends on writing reviews.
  • You use a review service where you can rate buyers based on their reviews.
  • You use a review service where customers register their Amazon public profile so that you can monitor their reviews of your products.

Incentivising customer reviews violates our policies and may violate the Federal Trade Commission Act.

The following actions are generally allowed, provided you comply with the above restrictions:

  • You may offer discounts that are generally available to all Amazon customers, such as Lightning Deals.
  • You may give out free products at trade shows, conventions or other similar venues where you are unable to monitor whether the recipients write a review or provide or withhold any benefits based on whether a review is written or the content of the review.

The above changes apply only to product categories other than books. We continue to allow the age-old practice of providing advance review copies of books.

£7,500,000,000 in lost revenue for UK companies, due to the online VAT Fraud that HMRC are failing to stop

The Rt Hon David Gauke MP announced that online VAT fraud accounts for up to £1.5billion of the total VAT gap. However it’s costing a lot more than that; £1.5billion of evaded VAT equates to £7.5billion in lost sales revenue for UK companies.

These UK companies are the ones funding HMRC and paying the £2.4 million pension pot for the most useless ex CEO of HMRC ever; Lin Homer.

The missing £7,500,000,000 is ending up in Chinese bank accounts without any VAT being paid. It’s also completely disappearing from the UK economy with no benefit to anyone other than the VAT Evaders and Amazon & eBay shareholders who are profit from vat fraud.

No corporate tax is being paid on the profits of the missing £7,500,000,000, no PAYE or NI is being paid on staff wages, no staff wages are being paid, no rent is being paid to landlords, no warehouse rates are being paid to local councils, no money is being spent on office furniture & equipment, no tea is being bought for the office, no pay packets are being spent down the local boozer on a Friday night, no kebabs are being bought at the end of the night and no taxi fares being paid to get home.

Instead, UK companies are going bust, staff are being made redundant, warehouses are being left empty, mortgages are going unpaid and the UK benefits bill keeps rising to astronomical levels.

These UK entrepreneurs have paid more Corporation tax than Amazon & eBay have ever paid.

We met with The Rt Hon David Gauke MP on 30th October 2015, who at the time was Financial Secretary to the Treasury, but has now been promoted to Chief Secretary to the Treasury.

At the time of our meeting he was completely unaware of this multi £billion Online VAT Fraud. He listened to us and got the wheels in motion with new legislation. We think our press coverage & meetings with the Heads of the EU VAT Unit helped.

However HMRC are still woefully slow and way behind the curve in taking effective action. HMRC are putting UK entrepreneurs out of business and are having a catastrophic effect on the UK economy as they fail take action against the VAT evading sellers.

HMRC are now issuing thousands of VAT numbers to NON UK sellers who have been evading VAT for years.

HMRC have failed to make a single prosecution for Online VAT Fraud in the past 5 years.

How much more pain do UK businesses have to suffer before HMRC take decisive action and stop the very crude and easy to spot fraud?

By allowing VAT Fraud to continue HMRC has created a huge market distortion in unfair competition and pricing for UK businesses. HMRC are responsible for allowing the marketing distortion to continue.

The key principle of the EU VAT Directive is that Member States (HRMC) are obligated to prevent VAT evasion, avoidance, and abuse to maintain non-distortion and fiscal neutrality of the market.

HMRC are clearly in breach of this principle and need to be held to account for the damage they are causing.

How much longer do UK businesses have to wait for HMRC to level the playing field?


UK Sellers v Chinese Sellers Rugby Match. eBay & Amazon staff & shareholders are cheering China on. HMRC are refereeing & the linesmen. Guess who is paying for the match and which side UK Sellers are on?

Here is The Rt Hon David Gauke MP full statement after the 2016 March Budget:

(Quote from HMRC Fulfilment House Due Diligence Scheme.PDF)

“The growth in online shopping has meant the average UK consumer can get goods faster and cheaper than ever before. According to a recent British Retail Consortium report, more than 20 per cent of non-food retail spending occurs online in the UK. This growth in online e-commerce has benefited the wider UK economy but has also left it open to severe abuse.

Non-EU traders who sell goods (located in the UK at the time of sale) to UK consumers, mainly via online marketplaces, are not always paying the correct VAT and duty to HMRC. These goods are normally shipped to the UK prior to sale and stored in fulfilment houses close to their final delivery point. This abuse has grown significantly and now accounts for £1-1.5bn of the total VAT gap. These overseas traders are unfairly undercutting all businesses trading in the UK, abusing the trust of UK consumers and depriving the government of significant revenue.

The government has announced at Budget 2016 a comprehensive package of measures to disrupt and deter this 21st century fraud. We are targeting non-compliant overseas traders themselves by making them appoint a UK tax representative who will be liable for their VAT and/or seeking a security. If these traders fail to comply and online marketplaces do not help stop the abuse occurring, the online marketplaces themselves will become jointly and severally liable for the unpaid VAT. We will be working with international partners to try to develop solutions to this problem that affects all major economies. Work has already begun on engagement with the EU and OECD on this matter.

The Fulfilment House Due Diligence Scheme complements the above measures, equipping HMRC with the tools it needs to tackle this fraud. The government will make sure fulfilment houses who are part of this scheme perform proper due diligence on the goods that they fulfil. This will ensure that HMRC can target those traders who use this business model to undercut legitimate business and protect revenue.

This consultation will ensure we minimise as far as possible the scheme’s impact on legitimate firms that import goods. It is therefore crucial that any business that is involved in storage, breaking bulk, unpacking, re-packing and/or subsequent delivery to customers of imported goods responds to this consultation. I hope that you take the time to respond fully. Your responses will help us to ensure this scheme is designed in a way that best meets its objectives, including ensuring the costs faced by firms are minimised.”