Why can't goods exported from Northern Ireland to the EU be zero-rated under section 30(6)?

Paragraph 9 of Schedule 9ZB modifies section 30(6) so that 'export of goods' excludes goods sent from Northern Ireland to EU member states. Under the Windsor Framework, Northern Ireland follows EU VAT rules on goods, meaning such movements are treated under EU intra-community supply rules rather than standard UK export zero-rating provisions.

How does the Windsor Framework affect VAT on goods moved from Northern Ireland to EU countries?

The Windsor Framework requires Northern Ireland to continue following EU VAT rules for goods. Movements of goods from Northern Ireland to EU member states are not treated as exports under UK VAT law. Suppliers must account for VAT under EU intra-community supply rules instead of applying the UK zero rate under section 30(6).

What must a Northern Ireland business do when selling goods to an EU customer?

A Northern Ireland business sending goods to an EU customer cannot zero-rate the supply as an export under section 30(6). Instead, it must treat the movement under EU intra-community supply rules applicable to Northern Ireland and consider whether relief is available under those rules, accounting for VAT accordingly.

Can a Belfast manufacturer zero-rate a sale of machinery to a customer in Dublin?

No. Although UK export rules would normally allow zero-rating under section 30(6), paragraph 9 of Schedule 9ZB prevents this because the goods are exported from Northern Ireland to an EU member state. The manufacturer must instead apply EU intra-community supply rules and account for VAT accordingly.

Value Added Tax Act 1994 section 30(6)

Goods exported from Northern Ireland

Schedule 9ZB paragraph 9 modifies the zero-rating rules for goods exported from Northern Ireland to EU member states.

Under normal UK VAT rules, goods exported by a supplier can qualify for zero-rating under section 30(6).
This paragraph restricts that zero-rating where goods are exported from Northern Ireland to an EU member state.
The restriction reflects Northern Ireland's unique position under the Windsor Framework, where EU VAT rules on goods continue to apply.
Suppliers exporting goods from Northern Ireland to EU member states must therefore account for VAT rather than applying the zero rate.

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