EU dispatches can only be zero rated if the customer is EU VAT registered. HMRC expect taxpayers to take ‘reasonable steps’ to confirm the validity of their customer’s EU VAT registration numbers. HMRC say that a person has failed to take reasonable steps if:

1he uses a VAT registration number which does not conform to the published format for his customer’s member state;

2he does not regularly verify the VAT number with HMRC or the Europa website;

3he continues to use a VAT registration number when HMRC have advised him that it is invalid; and

4he uses a VAT registration number which he knows does not belong to his customer

(Notice 725, para. 4.11 (2016 edn)).

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