It was widely expected that there would be significant changes to the VAT registration threshold either by increasing or decreasing the current threshold of £90,000. In the end, nothing happened which will frustrate those calling for an end to the current cliff-edge for SMEs.
There are changes to the VAT rules for ride-hailing apps such as Uber, removing their access to the Tour Operators Margin Scheme from 2 January 2026. This has been called for by traditional taxi firms to level the playing field and will increase the amount of VAT that the apps must account for as they are no longer able to account for VAT on their margin.
All VAT invoices will have to be raised in a specified electronic format from April 2029 which was expected following the end of the consultation earlier in the year. There is no more detail until Budget 2026, so this is clearly a work in progress for the government.
Other VAT changes include VAT relief for businesses donating goods to charities, 20% VAT on top-up payments for Motability cars, notification of an increase in the penalties due for late payment of VAT from 1 April 2027 and clarifying cross-border VAT group rules.
The main change for customs is the removal of the £135 threshold for customs duty for low value imports. This was widely called for by UK based retailers who pay customs duty on the goods that they sell whereas imports below £135 do not. This will be implemented by March 2029 and there will be a consultation period until 6 March 2026. It will be interesting to see if the timeframe is shortened given the potential amounts involved.
In today’s Autumn Budget, the UK government confirmed its intention that the longstanding Low Value Import (LVI) relief for goods valued at £135 or less will be removed, with new customs and VAT arrangements to be introduced by March 2029 at the latest.
This move is part of a broader effort to modernise the UK’s customs regime, improve compliance, and support domestic retailers.
The European Union has stated it will remove its €150 low-value customs threshold as soon as possible in 2026, and in the United States, the ($800) de minimis threshold was removed in August. These developments reflect a coordinated international move towards greater oversight of low value imports.
The government has issued a consultation document which outlines the following proposed changes to the UK’s treatment of low value imports:
These proposals are closely aligned with the direction of EU customs reform, which will also see the removal of low value duty relief, increased data requirements, and a shift in responsibility for customs and VAT to sellers and online marketplaces.
All low value consignments will become subject to the UK Global Tariff, in line with all imports which today exceed the de minimis threshold. The current BIRDS declaration will be replaced by a new system requiring detailed, item-level data, including product descriptions, values, and consignor/consignee information.
A key change is that sellers and online marketplaces will be directly responsible for paying customs duty to HMRC on a quarterly basis. Non-UK-established businesses may need to appoint a UK-based fiscal representative, who will be jointly and severally liable for customs debts. The government is also consulting on introducing a handling or administrative fee, which could be charged per consignment, per item, or per product type.
Certain goods, such as excise, restricted, or those subject to trade remedies, will be excluded from the new LVI arrangements and must use standard customs procedures. Relief for non-commercial consignments (gifts) sent between private individuals valued at £39 or less will remain.
VAT will continue to be due on all imports, but the process will be further aligned with the new customs arrangements. VAT will be calculated on the customs-inclusive value of goods, so customs duty will itself become part of the VAT base. The government is considering integrating VAT and customs duty collection into a single process for LVIs, allowing both to be paid together via a unified system.
For non-UK-established sellers and marketplaces, the requirement to appoint a UK-based fiscal representative may extend to VAT debts as well as customs. For goods excluded from the new LVI arrangements, VAT will continue to be collected at the border as part of the standard import process.
The consultation is open until March 2026, with implementation expected by March 2029. Businesses should review their processes, assess data and system readiness, and consider the implications of fiscal representation. Engagement with the consultation is recommended to ensure practical challenges are addressed.
While the changes will require significant adjustments for businesses involved in cross-border e-commerce, the extended implementation period provides time to prepare.
Crowe’s customs team is available to support clients in understanding the impact, responding to the consultation, and preparing for the transition.
For further information, explore our ...
Customs-ID - giving your business visibility of your customs duty exposure and compliance profile
Any top-up payments for Motability cars will be liable to VAT at 20% from July 2026 and Insurance Premium Tax will be applied at the standard rate of 12% on insurance for vehicles leased through the scheme.
The tax position for Private Hire Vehicle Operators (PHVOs) has been subject to high-profile litigation in recent years and following on from this, the Chancellor announced changes to how certain PHVOs account for VAT. The changes aim to prevent PHVOs from exploiting an administrative VAT scheme—The Tour Operator’s Margin Scheme (TOMS).
From 2 January 2026, PHVOs that operate as ‘principal’ can no longer declare VAT via TOMS which previously allowed these PHVOs to declare VAT on the margin made per journey rather than on the full selling price. PHVOs acting as ‘agents’ for a named principal or those not using TOMS are unaffected but may benefit indirectly through a more level playing field.
Consumers may also be impacted if affected PHVOs decide to pass on the additional VAT burden.
The consultation on e-invoicing finished in May 2025 and it has been confirmed that all VAT invoices must be issued in a specified electronic format from April 2029. Further details will be published at Budget 2026 after further consultation with stakeholders. It was widely expected that the UK would mandate e-invoicing but there is no confirmation that this will also include real-time reporting, which would increase the amount of information received by HMRC on a real-time basis. This will impact anyone issuing VAT invoices, who should continue to monitor the developments.
The government has announced a consultation on reforming VAT rules to incentivise the development of land intended for social housing. Pressure has been mounting for several years to change the definition of when land can be sold zero-rated by a developer to a housing association. Currently, HMRC insist that a building needs to be beyond ‘golden ’brick’—normally the point when walls start being constructed above the foundations. Allowing land to be sold before work has started without a VAT cost, or at least changing the definition of golden brick to one that takes account of modern methods of construction, would be welcomed by housing associations and commercial developers alike.
In a change to guidance published in 2015, HMRC are now of the view that where a member of a UK VAT group has an overseas establishment, that establishment is part of the VAT group in all circumstances. Any businesses that have overpaid VAT based on the previous guidance can make a claim for overpaid VAT in the normal way.