TL;DR: VAT/GST registration is mandatory once you exceed the turnover threshold in each country, and carries strict invoicing and filing obligations. Voluntary registration below the threshold often makes sense for B2B businesses that want to recover input tax from day one.
Value Added Tax (VAT) and Goods and Services Tax (GST) are consumption taxes charged on most business sales of goods and services. They are the largest source of tax revenue for most governments and the most administratively demanding tax for small businesses to manage.
The mechanics are straightforward: you charge VAT/GST on your sales (output tax), you pay VAT/GST on your purchases (input tax), and you remit the difference to the government. If your output tax exceeds your input tax (normal for most businesses), you pay the difference. If your input tax exceeds your output tax (common for exporters and businesses in early growth stages with high capital investment), you receive a refund.
The complexity lies in: knowing which of your products and services are taxable (and at what rate), understanding the thresholds and timing of registration, issuing compliant VAT invoices, and filing returns accurately on time.
Most jurisdictions apply multiple rates:
Standard rate: Applied to most goods and services
Reduced rates: Applied to specified categories (food, healthcare, residential property in the EU; no reduced rates in Australia or NZ)
Zero rate: Taxable supply but at 0% (often exports, international services, some food items)
Exempt: Not subject to VAT at all — and the seller cannot recover input VAT on related costs
The distinction between zero-rated and exempt is critical: if your sales are zero-rated, you can still reclaim input VAT on your costs (making you effectively a VAT-free business). If your sales are exempt, you cannot reclaim input VAT — the VAT on your costs becomes an irrecoverable cost.
Standard rates (2024):
You must register for VAT/GST when your taxable turnover reaches the threshold. Key dates: in most countries, the trigger is either when you exceed the threshold over the past 12 months, or when you expect to exceed it in the next 30 days.
| Country | Mandatory Registration Threshold | Optional Early Registration? |
|---|---|---|
| UK | GBP 90,000 | Yes |
| France | EUR 91,900 (goods) / EUR 36,800 (services) | Yes (under certain conditions) |
| Sweden | SEK 80,000 | Yes |
| Australia | AUD 75,000 (or AUD 150,000 for non-profits) | Yes |
| New Zealand | NZD 60,000 | Yes |
| Canada | CAD 30,000 | Yes |
| USA | Varies by state (nexus threshold) | Yes (in most states) |
If you are below the registration threshold, you can still register voluntarily in most countries. Should you?
Arguments for voluntary registration:
Arguments against:
For most B2B businesses, early voluntary registration is usually advisable. For B2C businesses below the threshold, the calculation is more nuanced.
Many countries offer simplified schemes for small businesses:
UK Cash Accounting Scheme: Pay VAT when your customers pay you (not when you invoice them). Useful for businesses with slow-paying customers. Available if taxable turnover is below GBP 1.35M.
UK Flat Rate Scheme: Pay a fixed percentage of gross turnover (varying by industry, 4–16.5%) instead of calculating actual VAT on each transaction. Simplifies administration for very small businesses.
Australian GST Cash Basis: GST is accounted for when cash is received/paid rather than when invoiced.
French Franchise en Base: Exemption from charging VAT if below threshold — but no input VAT recovery.
Canada Quick Method: Simplified calculation for small businesses (taxable supplies below CAD 400,000).
Once registered, you must file VAT/GST returns at specified intervals:
Returns must be filed on time even if the amount is nil. Late filing penalties apply in all jurisdictions.
Use our free tool: Cost Calculator
Try it free →| Country | Standard Rate | Key Filing Deadline | Late Payment Penalty | VAT Portal |
|---|---|---|---|---|
| 🇬🇧 UK | 20% | 1 month + 7 days after quarter end | 2–15% surcharge | gov.uk/vat-returns |
| 🇫🇷 France | 20% | Varies by regime | 5–80% penalties + interest | impots.gouv.fr |
| 🇸🇪 Sweden | 25% | 12th of second month after reporting period | Interest + surcharge | skatteverket.se |
| 🇦🇺 Australia | 10% | 28th of month after quarter end | GIC interest | ato.gov.au/gst |
| 🇳🇿 New Zealand | 15% | 28th of month after filing period | UOMI (interest) | ird.govt.nz |
| 🇨🇦 Canada | 5% federal | One month after period end | 6% annual interest | canada.ca/gst-hst |
| 🇺🇸 USA | Varies (state) | Varies by state | Varies | State revenue department websites |
MmowW Scrib🐮 helps prepare the document frameworks for VAT registration applications.
MmowW Scrib🐮 is a document preparation service, not a law firm. We do not provide legal advice. For specific VAT/GST advice, always consult a qualified accountant or tax advisor in your jurisdiction.
Q: Do I charge VAT/GST on international sales?
A: Generally: goods exported to overseas customers are zero-rated (you charge 0% VAT/GST but can reclaim input VAT/GST). Services exported to overseas business customers (B2B) are typically outside the scope of VAT/GST in the supplier's country under the "place of supply" rules. Services sold to overseas consumers (B2C) may require you to register and charge VAT/GST in the customer's country — this is the EU's OSS (One Stop Shop) regime for digital services. The rules are complex and depend on the nature of the service and the customer's location. Consult a qualified tax advisor.
Q: Can I reclaim VAT paid before my business was VAT-registered?
A: Yes, in most countries. In the UK, you can reclaim VAT on goods purchased up to 4 years before registration (if still in use) and on services purchased up to 6 months before registration. Similar provisions exist in Australia (4 years) and most EU countries. Keep pre-registration VAT invoices — they have value.
Q: What is Making Tax Digital (MTD) in the UK?
A: Making Tax Digital for VAT requires VAT-registered businesses in the UK to maintain digital records and submit VAT returns using compatible software (via HMRC's API) rather than manually entering data on HMRC's website. MTD for VAT applies to all VAT-registered businesses (from April 2022). MTD for Income Tax (self-assessment) is planned from April 2026 for businesses and landlords with income above GBP 50,000. Non-compliance risks penalties. Most modern accounting software (Xero, QuickBooks, FreshBooks) is MTD-compatible.
Loved for Safety. MmowW Scrib🐮 — Document preparation made simple across 7 countries.
Free tools to help you get started:
MmowW Scribe prepares your formation documents, compliance filings, and business paperwork across 7 countries.
Start 14-Day Free Trial →No credit card required. From $149/month.
Loved for Safety.
Lass dich nicht von Vorschriften aufhalten!
Ai-chan🐣 beantwortet deine Compliance-Fragen 24/7 mit KI
Kostenlos testen