In short: a German wholesaler selling into the UK on DDP terms discovered, years in, that it should have been UK VAT registered since 1 January 2021. We put the whole position right: backdated registration, penalties reduced to zero, retrospective re-invoicing so the VAT did not fall on the business, and GBP 100,000 of import VAT recovered.
A German wholesaler had been selling into the UK on DDP (Delivered Duty Paid) Incoterms® for several years. One of its UK customers got in touch to ask why it had not been charged UK VAT.
When the UK left the EU, with effect from 1 January 2021, the simplifications that had meant the business did not need to be UK VAT registered stopped applying. So, without realising it, the business had had a UK VAT registration obligation since that date, and a growing exposure.