For our members in Northern Ireland, Andrea has reproduced the entire Check if you're trading under the Northern Ireland protocol and what to do Policy Paper below, but it does raise the following questions/points:
- it would appear that members will need to notify HMRC that they are "trading under the protocol" because presumably the VAT reg certificate of universties will show a type of business that is solely involved in the provision of services - unfortunately there is no guidance on how you notify HMRC
- as we thought, you will need to notify EU suppliers of your XI EORI number when goods are moved from the EU to Northern Ireland
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Check if you’re trading under the protocol
You’re trading under the protocol if your business is VAT registered and either:
- your goods are located in Northern Ireland at the time of sale
- you receive goods in Northern Ireland from VAT registered EU businesses for business purposes
- you sell or move goods from Northern Ireland to an EU member state
You’ll need to be identified within HMRC’s VAT systems if you’re making transactions that fall within the scope of the protocol.
You’ll be automatically identified as falling within the scope of the protocol if your:
- VAT registered address has BT postcode
- VAT registration certificate shows a type of business that is not solely involved in the provision of services
If you’re not identified with HMRC’s VAT systems
You’ll not be eligible for certain VAT simplifications that operate inside the EU and your suppliers may not be able to zero rate goods that they dispatch to you.
You’ll need to notify HMRC if you believe you are trading within the protocol.
What you’ll need to do
If you are trading and make transactions under the protocol, you’ll need to:
- put an “XI” prefix in front of your VAT number when communicating with an EU customer or supplier (your invoices will show an XI number ahead of your VAT number - for example, XI 123456789 - instead of GB)
- complete an EC sales list when selling goods from Northern Ireland to VAT registered customers in the EU
You may also be able to access the EU VAT Refund system in certain circumstances. Check VAT refunds guidance for more information
23 November 2020 
Andrea Marshall, Tax Specialist
