VAT and GST are charged where a supply is treated as taking place, not where the supplier is based. For most business-to-business services the place of supply is the customer's country and the customer self-accounts under the reverse charge, but non-resident suppliers can still have to register, especially for consumer sales and goods held locally. Rates and invoicing rules differ sharply between markets, and real-time e-invoicing is spreading from Saudi Arabia and India to the EU, France, Germany and the UAE.
Place of supply decides which country's VAT applies
The first question for any cross-border sale is where it is taxed. In the EU, the general rule for services sold to another business is that they are taxed where the customer has established its business, while services sold to consumers are generally taxed where the supplier is established. The UK follows the same logic: B2B services are supplied where the customer belongs. Specific rules override the general ones for services such as those connected with land, events, transport and digital services to consumers.
This matters commercially because it decides whose rate applies, whether the supplier must register abroad, and what the invoice must say. A UK or German group selling consulting services to a client in another country normally charges no local VAT on a B2B basis, but the same service sold to individuals may be taxable in a different place.123
The reverse charge moves the obligation to the customer
When a business buys services from a supplier abroad, it usually accounts for the VAT itself. In the EU the supplier does not normally charge VAT on B2B services to another Member State; the customer applies its own country's rate. In the UK the recipient records the VAT as both output and input tax. In India, liability shifts to the recipient in notified cases, which include imports of services, and IGST is the tax that applies to imports.
For a fully taxable business the reverse charge is usually cash-neutral, because the same amount is recovered as input tax. It is not neutral for businesses that make exempt supplies, such as many financial services firms, which bear the cost. Missing a reverse-charge entry is still an error that can attract penalties even when no net tax is lost.4356
Registration as a non-resident
Thresholds that protect small local businesses often do not protect foreign ones. The UK requires a business based outside the UK to register regardless of turnover if it makes taxable supplies there, while UK-established businesses register above GBP 90,000. The UAE requires residents to register above AED 375,000 but applies no threshold to non-residents making supplies on which UAE VAT must be charged. Goods sold to EU businesses with valid VAT numbers move without VAT, but holding stock in another country usually creates a registration there.
Before the first invoice, map each revenue stream to where it is taxed and whether the supplier, the customer or a marketplace accounts for the tax. This determines whether a registration is needed before trading starts.78910
E-invoicing and real-time reporting
Tax authorities increasingly receive invoice data directly. Saudi Arabia's e-invoicing has applied to resident taxpayers since December 2021, with integration into ZATCA's systems rolled out in waves since January 2023. India requires B2B e-invoices above an INR 50 million turnover threshold. Germany's transition ends for most issuers with supplies made after 2026, with a 2027 extension only for issuers with prior-year turnover up to EUR 800,000. France's obligation started on 1 September 2026 for large and intermediate-sized companies and follows on 1 September 2027 for smaller firms. The UAE has set implementation for businesses with revenue of AED 50 million or more from 1 January 2027.
Across the EU, the VAT in the Digital Age package makes e-invoicing the default and introduces digital reporting for intra-EU transactions from 1 July 2030. For a group, this turns invoicing into a systems project: ERP data quality, customer master data and approved service providers have to be in place before the go-live date in each country.111213141516
| Market | Standard rate | Non-resident registration | E-invoicing status |
|---|---|---|---|
| UAE | 5% | No threshold for non-residents making taxable supplies | AED 50m+ revenue: implement by 1 January 2027; others by 1 July 2027 |
| Saudi Arabia | 15% (since 1 July 2020) | Not confirmed (see gaps) | Phase One since 4 December 2021; Phase Two in waves since 1 January 2023 |
| India (GST) | Main slabs 5% and 18%; 40% for certain supplies | Reverse charge by recipient on imported services in notified cases | B2B e-invoicing above INR 50m turnover since 1 August 2023 |
| Germany | 19% | EU rules | Paper and other formats allowed only in transition to end-2026 (end-2027 for issuers up to EUR 800,000) |
| France | Not confirmed on an opened page (see gaps) | EU rules | Large and intermediate companies from 1 September 2026; SMEs and micro from 1 September 2027 |
| UK | 20% | Must register regardless of turnover if making UK taxable supplies | No mandate confirmed |
Decisions to make
- Is the customer a business or a consumer?124B2B services generally follow the customer and are reverse-charged; B2C services generally follow the supplier, except digital services and other specific categories, which can require registration in the customer's country.
- Do we need to register before the first sale?910Non-residents often have no threshold (UK, UAE). Holding stock, running events or selling to consumers usually triggers registration even when B2B services do not.
- Are our systems ready for e-invoicing in each country?111215Go-live dates differ by country and by company size; check the dates that apply to the local entity, not the group.
Documents usually needed
- Customer VAT or GST registration numbers and evidence of business status (for example a VIES check for EU customers)
- Contracts and statements of work showing who receives the service and where it is used
- Invoices meeting each country's content and format rules, including reverse-charge wording
- Non-resident VAT registration applications and, where required, a local tax representative appointment
- Import and transport documents for goods
- E-invoicing service provider agreements and system certification records
Common mistakes
- Assuming a foreign supplier is below the local registration threshold, when non-residents have no threshold in markets such as the UK and the UAE.
- Not recording the reverse charge on imported services because no VAT was charged on the invoice.
- Treating a customer as a business without evidence of its VAT status.
- Planning e-invoicing at group level and missing an earlier local go-live date for a large subsidiary.
- Assuming VAT is always a cost-neutral pass-through; exempt businesses cannot recover reverse-charged VAT.
Questions businesses ask
We sell software consulting from the UK to a German company. Who pays German VAT?
Under the EU general B2B rule the service is taxed where the customer is established, and the German customer normally accounts for VAT under the reverse charge. The UK invoice does not normally carry UK VAT because, under UK rules, B2B services are supplied where the customer belongs.143
Our Indian subsidiary pays a UAE group company for management services. Is there GST?
Imports of services into India are subject to IGST, and in notified cases, which include imports of services, the Indian recipient pays under the reverse charge and may claim input credit subject to conditions.56
When does the EU require e-invoicing for cross-border sales?
The VAT in the Digital Age directive applies e-invoicing as the default and digital reporting for intra-EU transactions from 1 July 2030. Individual Member States such as France and Germany already require domestic e-invoicing on their own timetables.111213
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- Saudi Arabia's VAT registration thresholds and non-resident registration rules, and the UAE rule on reverse charge for imported services, were not confirmed on an official page; the ZATCA and Federal Tax Authority pages opened did not state them or blocked automated access.
- France's standard VAT rate and Germany's and France's separate receipt and issuance dates for e-invoicing were not confirmed on an opened official page.
- The UAE e-invoicing dates and the UAE, Saudi and Indian rates rely on secondary summaries; confirm on mof.gov.ae, tax.gov.ae, zatca.gov.sa and cbic-gst.gov.in.
- India's registration and payment regime for non-resident suppliers of online information and database access services to unregistered recipients was not confirmed.
- Place-of-supply exceptions (land, events, transport, digital services) need checking service by service.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 18 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
Under the EU VAT Directive, the general place of supply of services to a taxable person acting as such is where that customer has established its business (or the fixed establishment receiving the service). Business-to-business (B2B) services; general rule only, subject to specific rules for property, transport, events, restaurants and others.
Under the EU VAT Directive, the general place of supply of services to a non-taxable person (a consumer) is where the supplier has established its business. Business-to-consumer (B2C) services; general rule only. Telecommunications, broadcasting and electronically supplied services are taxed where the customer is located.
In the UK, B2B services are generally supplied where the customer belongs, and a UK business receiving such services from an overseas supplier accounts for the VAT itself under the reverse charge. Almost all B2B supplies of services except exempt supplies; special place-of-supply rules apply to some services.
For B2B services supplied to a business in another EU country, the supplier does not usually charge VAT; the customer accounts for VAT at its own country's rate through the reverse charge. Cross-border B2B services within the EU; the EU guidance notes several important exceptions.
India's Goods and Services Tax has three components: central GST and state or union territory GST on intra-state supplies, and integrated GST (IGST), levied by the Centre, on inter-state supplies including imports. Central vs state split; IGST equals the combined CGST and SGST/UTGST rate.
Secondary source; confirm in the IGST Act, 2017 on cbic-gst.gov.in.
In India, liability to pay GST shifts from the supplier to the recipient under the reverse charge in notified cases, which include imports of services. Notified categories; registered recipients in India pay IGST on imported services and may claim input credit subject to conditions.
Secondary source; the specific IGST notification could not yet be checked. Online information and database access services supplied by non-residents to unregistered recipients follow a separate supplier-registration regime that was not confirmed.
For goods sold to a business in another EU country, the seller does not charge VAT if the customer has a valid EU VAT number, which can be checked in the VIES system. Intra-EU B2B supplies of goods; conditions on transport and evidence apply.
A UK business must register for VAT when its taxable turnover for the last 12 months goes over GBP 90,000, or when it expects to go over that in the next 30 days alone. UK-established businesses.
A business based outside the UK must register for UK VAT regardless of turnover if it makes, or expects to make within the next 30 days, taxable supplies of goods or services in the UK. Non-established taxable persons; no registration threshold applies.
UAE-resident businesses must register for VAT when taxable supplies exceed AED 375,000 (voluntary registration from AED 187,500), while no registration threshold applies to non-resident businesses making supplies on which UAE VAT must be charged. Mainland and free zone businesses alike, subject to designated zone rules for goods.
Secondary source; confirm on tax.gov.ae. The 12-month measurement basis for the threshold is not stated here.
Germany allows B2B invoices in paper or non-standard electronic formats only during a transition: for supplies made up to 31 December 2026, and for supplies in 2027 only where the issuer's prior-year total turnover did not exceed EUR 800,000 (or where EDI is used). Domestic B2B invoices between businesses established in Germany; after the transition, invoices must follow the structured e-invoice format in § 14 UStG.
The page sets out the issuing transition only. The general obligation for German businesses to be able to receive structured e-invoices from 1 January 2025 is widely reported but was not confirmed on a page opened.
France's B2B e-invoicing obligation applies from 1 September 2026 for large and intermediate-sized companies and from 1 September 2027 for small and medium-sized enterprises and micro-enterprises. VAT-registered businesses established in France transacting with each other; set by Article 91 of the 2024 Finance Law as amended. The page does not separate receipt and issuance dates.
impots.gouv.fr confirms the reform has been effective since 1 September 2026. Under the published scheme all businesses must be able to receive e-invoices from 1 September 2026; this was not separately confirmed on the pages opened.
The EU's VAT in the Digital Age (ViDA) directive makes electronic invoicing the default and introduces digital reporting for intra-EU transactions, with Member States applying those measures from 1 July 2030. Article 5 measures (e-invoicing rules, cross-border digital reporting, removal of recapitulative statements); Member States with an existing domestic real-time reporting system by 1 January 2024 have until 1 January 2035 for the domestic part. Member States may already require domestic e-invoicing for established businesses.
Saudi e-invoicing Phase One (generation) has applied since 4 December 2021 to all taxpayers except non-resident taxpayers, and Phase Two (integration with ZATCA's systems) has been rolled out in waves since 1 January 2023. Resident VAT taxpayers and parties issuing invoices on behalf of VAT-registered suppliers; wave selection is notified by ZATCA.
The UAE e-invoicing system (Ministerial Decisions No. 243 and 244 of 2025) requires businesses with annual revenue of AED 50 million or more to appoint an accredited service provider by 31 July 2026 and implement by 1 January 2027; businesses below that revenue must appoint by 31 March 2027 and implement by 1 July 2027. Businesses in the UAE within scope of the system; government entities implement by 1 October 2027.
Secondary source: Ministry of Finance pages could not yet be checked by automated access. Confirm the decisions on mof.gov.ae.
India's B2B e-invoicing requirement, introduced on 1 October 2020 for taxpayers with turnover above INR 500 million, has applied to taxpayers with turnover above INR 50 million since 1 August 2023. GST-registered businesses above the aggregate turnover threshold; some sectors are exempt.
Secondary source; confirm on the GST portal or CBIC notifications.
Germany's general VAT rate is 19% of the taxable amount. Standard rate; reduced rates apply to listed supplies.
The UK standard VAT rate is 20%. Standard rate; reduced and zero rates apply to listed supplies.
Saudi Arabia's standard VAT rate is 15%, increased from 5% with effect from 1 July 2020. Standard rate.
Secondary source: the ZATCA VAT page opened did not state the rate. Confirm on zatca.gov.sa.
The UAE general VAT rate is 5% and applies to most goods and services. Standard rate; zero-rated and exempt categories exist.
Secondary source: the Federal Tax Authority VAT page could not yet be checked by automated access. Confirm on tax.gov.ae.
India's main GST rate slabs are 5% and 18%, with most supplies at 18%, and a 40% rate for certain supplies. Some supplies carry other effective rates (for example 12%).
Secondary source; confirm the rate for a specific supply in CBIC rate notifications.
Questions on this topic
23 statements on vat and gst on cross-border goods and services
