Thanks for your input. Just to clarify, this is regarding B2B sales to an EU VAT registered company, distance sale fulfilled from UK stock direct to the customer. The main thing I’m looking for is evidence of removal of goods. I don’t believe an invoice on it’s own is enough, it should be accompanied by some sort of certificate of export or proof of delivery. See below notes from HMRC regarding evidence of removal, even this official advice is annoyingly vague, good job HMRC. It says a combination of documents is needed and I don’t believe an invoice on its own is evidence of removal of goods, so in theory Amazon needs to provide us with supplementary evidence such as a POD. Looking again it seems like a tracking number from certain courier companies might also be enough evidence, so maybe we can get these on an Amazon report?

HMRC guidance below:

5. Zero rating supplies to VAT-registered customers in another member state

5.1 Evidence of removal

A combination of these documents must be used to provide clear evidence that a supply has taken place, and the goods have been removed from the UK:

• the customer’s order (including customer’s name, VAT number and delivery address for the goods)
• inter-company correspondence
• copy sales invoice (including a description of the goods, an invoice number and customer’s EU VAT number)
• advice note
• packing list
• commercial transport documents from the carrier responsible for removing the goods from the UK, for example an International Consignment Note (CMR) fully completed by the consignor, the haulier and signed by receiving consignee
• details of insurance or freight charges
• bank statements as evidence of payment
• receipted copy of the consignment note as evidence of receipt of goods abroad
• any other documents relevant to the removal of the goods in question which you would normally get in the course of your intra-EU business

Photocopy certificates of shipment or other transport documents are not normally acceptable as evidence of removal unless authenticated with an original stamp and dated by an authorised official of the issuing office.

5.2 What to show on documents used as proof of removal

The following paragraph including bullet points has force of law

The documents you use as proof of removal must clearly identify the following:

• the supplier
• the consignor (where different from the supplier)
• the customer
• the goods
• an accurate value
• the mode of transport and route of movement of the goods, and
• the EU destination

Vague descriptions of goods, quantities or values are not acceptable. For instance, ‘various electrical goods’ must not be used when the correct description is ‘2,000 mobile phones (make ABC and model number XYZ2000)’. An accurate value, for example, £50,000 must be shown and not excluded or replaced by a lower or higher amount.

If the evidence is found to be unsatisfactory you as the supplier could become liable for the VAT due.

5.9 Postal services

Goods sent by post may be zero-rated if they’re sent directly to your customer registered for VAT in another EU member state, and you hold the necessary evidence of posting. The receipted forms described, plus the Parcelforce Worldwide statement of account or parcel manifest listing each parcel or multi-parcel, will provide evidence of removal.

Letter post or airmail

A fully completed certificate of posting form presented with the goods, and stamped by the Post Office. Acceptable forms are:

• form C&E132 for single or multiple packages taken to the Post Office
• form P326 available from the Post Office and used for single packages taken to the Post Office, or a Certificate of Posting for international mail only, or a Royal Mail Collection Manifest, available from a Royal Mail sales adviser, for use by customers using their Business Collections Service, where the Royal Mail collection driver signs the certificate

You can find further information on Parcelforce Worldwide international services.

Parcels

Parcelforce Worldwide operates a range of international parcel services. If you use any of these services you will be provided with:

• a service specific barcoded label
• a customs export declaration (for non-EU destinations only)
• a copy of the Parcelforce Worldwide conditions of carriage
• a printed receipt, which is your proof of shipment for all destinations

An individual barcode label must be affixed to every parcel. You do not need to complete the customs export declaration for goods being sent to another EU member state.

If you arrange for the parcel to be collected from your premises the collecting driver will sign your printed receipt. This is your proof of shipment for EU destinations.

If the parcel is taken to a Post Office, the counter clerk will provide you with a printed proof of shipment from the Post Office SmartPost system. This will show the overseas delivery address, date of dispatch and unique consignment number. You should keep this printed proof of shipment as your evidence of removal.

In addition to the individual parcel declarations described above, account customers of Parcelforce Worldwide have 2 further potential sources of information listing multiple parcel dispatches. These are:

• Worldwide Dispatch manager (WDM) - online users can print a manifest which lists all dispatched parcels
• a Statement of Account

All of the individual parcel declarations, plus either the manifest or the statement of account listing each dispatch will provide proof of removal for VAT purposes.

You can find further information on Parcelforce Worldwide international services.

5.10 Couriers and fast parcel services

Courier and fast parcel operators specialise in the shipment of goods to overseas destinations within guaranteed timescales.

(a) Operators who do not issue separate certificates of shipment

Most courier and fast parcel operators do not issue separate certificates of shipment. The invoice for moving goods from the UK, which bears details of the unique airway bill numbers for each shipment, represents normal commercial evidence of removal. In addition, many express companies are able to offer a track and trace service on their websites where the movement of goods can be traced through to the final destination. This information can be printed and also be used to confirm removal from the UK.

(b) Operators who use the system based upon a dispatch pack

A few companies still use a documentary system based upon a dispatch pack containing accounting data, a customs export declaration and receipt copies of the relevant house airway bill or consignment note. These packs are issued to customers to complete for each removal from the UK.

An export declaration does not need to be completed for goods being sent to another EU member state but a dispatch pack must be completed for each overseas address and consignee. The driver collecting the parcels will endorse the receipt copy and return it to the consignor. This, plus the statement of account listing each removal, will provide evidence of removal from the UK.

© Use of more than one courier or fast parcel company

Due to the complexities of the movement of goods within the courier or fast parcel environment, there is often more than one company involved in the handling and ultimate removal of the goods. Ultimately, you as the UK supplier may not be certain as to which courier or fast parcel company has removed the goods. If you’re aware that this may happen you will need to establish what proof of removal you will receive from the company to whom you give your goods. The proof available is described in (a) and (b).

(d) Overseas customer arranging the removal by courier

If your EU customer arranges for the goods to be removed by courier you should ascertain what proof of removal they will be providing to allow you to zero rate the supply. You should consider taking a deposit equivalent to the amount of VAT you would have to account for if you do not hold satisfactory evidence of the removal of the goods from the UK. The deposit can be refunded when you get evidence that proves the goods were removed within the appropriate time limits.