Exporting goods from the UK

A recent UK VAT tribunal decision involving H Ripley & Co Ltd ([2025] UKUT 00210 (TCC)) has highlighted the complexities of VAT compliance when exporting goods from the UK. The case centred on HMRC’s challenge to the zero-rating of exports due to insufficient evidence of removal.

A timely reminder

In this case, the Upper Tribunal upheld HMRC’s decision to deny zero-rating on a series of exports, where the customer collected the goods and removed them from the UK. Although the company held documentation that prima facie indicated the goods were exported, the evidence – such as unsigned CMRs and unrelated ferry bookings – was either incomplete or submitted too late.

This decision reinforces a key principle; zero-rating depends not only on the fact of export, but on holding the right evidence at the right time.
While the outcome wasn’t groundbreaking, it serves as a timely reminder; VAT on exports is not just about getting goods out of the country, it’s about proving it too.

This article outlines the key VAT considerations for UK businesses exporting goods, with a particular focus on documentation, indirect exports, and the role of Incoterms® in determining VAT obligations.

VAT zero-rating – the essentials

When goods are exported outside the UK, they can generally be zero-rated for VAT. This means no VAT is charged on the sale, but the business can still reclaim VAT on related costs. However, to apply zero-rating, three conditions must be met:

1. goods must physically leave the UK
2. they must do so within a set time limit – usually three months from the date of sale
3. the exporter must retain sufficient evidence of removal.

Evidence can be:

• official (e.g. customs declarations via HMRC’s CDS system)
• commercial (e.g. waybills, bills of lading, or fully completed CMRs).

Incomplete or missing documentation can result in HMRC denying zero-rating, as seen in the H Ripley & Co case.

For more information on avoiding the VAT risks that arise from exporting goods from Great Britain to a country outside of the United Kingdom, please read our insight Exporting goods from Great Britain.

For further information on anything discussed in this article, please contact your usual Crowe contact.