B2B services VAT location check: UK Notice 741A rules

A UK surveyor bills a US investor £15,000 for a London building: the land rule beats the B2B customer rule, so £3,000 UK VAT is due, and leaving it off puts £3,900 at stake with HMRC's careless-inaccuracy penalty of up to 30%.

Your numbers

Your result

Charge UK VAT: £3,000.00 on £15,000.00. The service relates to land in the UK, so the UK rule beats the customer’s location. Leaving the VAT off puts £3,900.00 at stake.

Place of supply is the UK (1 = charge UK VAT, 0 = outside the scope of UK VAT)1
UK VAT to charge on this invoice£3,000.00
Invoice total£18,000.00
Net value outside the scope of UK VAT£0.00
Penalty if you leave the UK VAT off (careless)£900.00
At stake if you leave the UK VAT off (VAT + penalty)£3,900.00
UK VAT owed anyway if you charge it in error (Sch 11 para 5(2))£0.00
Amount riding on getting this invoice right£3,900.00
Taxed in another country: check VAT registration there (1 = yes)0
Missing business evidence made this a UK-VAT sale (1 = yes)0

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How the place of supply is decided (VAT Notice 741A)

Special rules first (para 6.1): a service directly related to a specific site of land is taxed where the land is (section 7: surveying, valuing, conveyancing, building work, property management). B2B admission to an event and restaurant or catering are taxed where they take place (section 9). Short-term hire of a means of transport (30 days, 90 for vessels) is taxed where it is put at the customer’s disposal (para 8.6).

Then the B2B general rule (para 6.3): supplied where the customer belongs. A UK supplier billing an overseas business customer charges no UK VAT, but must hold evidence: a VAT number, a certificate from the fiscal authority, or other commercial documents. Without it, the sale is treated as B2C, taxed where you belong (para 6.2), unless the service is on the section 12.2 list.

What you lose if you get it wrong: UK VAT left off a UK supply is assessed in full plus a careless-inaccuracy penalty of 0% to 30% unprompted or 15% to 30% prompted (HMRC CC/FS7a). UK VAT charged in error is still recoverable from you (VAT Act 1994 Sch 11 para 5(2)).

Why not the one-line rule: “B2B services are taxed where the customer belongs” gives the wrong answer for the London survey above: £3,000 of UK VAT is due even though the investor is in the US.

No risk: the check above is free and complete for your own invoice. The full version is your own file, one payment, no subscription.

Sources: HMRC VAT Notice 741A, Place of supply of services (gov.uk, last updated 29 September 2022); HMRC factsheet CC/FS7a (updated 20 July 2026); VAT Act 1994 Schedule 11 para 5 (legislation.gov.uk). Checked 18 October 2026.

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The .xlsx for a whole client ledger: a 40-invoice register that runs the same Notice 741A test on every line with a date, client and country column, totals of UK VAT due, outside-the-scope value and penalty exposure, a list of invoices that lack business evidence, and a 12-point evidence checklist f

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What a wrong call costs, from HMRC's own sources: UK VAT left off a UK-taxable supply is assessed in full plus a careless-inaccuracy penalty of 0% to 30% unprompted or 15% to 30% prompted (HMRC factsheet CC/FS7a, updated 2026-07-2

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