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Triangulation meaning

Published by a LexisNexis Tax expert
What does Triangulation mean?
Triangulation describes a chain transaction in which three or more businesses contract for the sale of the same goods, but the goods make a single journey directly from the first supplier to the final customer on the instruction of an intermediate supplier. In VAT practice, the term is widely used. In EU law it underpins the triangulation simplification for intra-Community supplies, which—if the conditions are met—lets the intermediate supplier avoid VAT registration in the destination state by zero‑rating its dispatch and requiring the final customer to account for VAT under the reverse charge. Post‑Brexit, treatment differs within the UK. The EU triangulation simplification continues to apply for movements of goods between Northern Ireland and EU Member States (under the Windsor Framework). It does not apply where goods move into or out of Great Britain, which are treated as imports/exports. In Ireland, the EU rules fully apply. Key features: three parties, two invoices, one cross‑border movement, no physical possession by the intermediate supplier, correct VAT numbers and invoice wording. Example: A (Germany) sells to B (France), B sells to C, and A ships straight to C in Northern Ireland on B’s instructions. Failing the conditions can trigger VAT registration, assessments and penalties.
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PRACTICE NOTES
Northern Ireland VAT: EU triangulation for goods under the Northern Ireland Protocol: conditions, procedures, chain transactions and non-EU scenarios

ARCHIVED: Following the reforms anticipated under The Windsor Framework, the details of which the UK government announced on 27 February 2023, this Practice Note has been archived and is no longer maintained. The information within this Practice Note is accurate as at 1 January 2021. For more on The Windsor Framework and its consequences for VAT in Northern Ireland, see: The Windsor Framework. This Practice Note addresses VAT as it applies to the movement of goods between Northern Ireland (NI) and the EU from 1 January 2021, and as it applied to all VAT-registered businesses in the UK on and before 31 December 2020. Triangulation is an EU-based VAT simplification intended to reduce the necessity for EU businesses to register for VAT in other EU Member States. Triangulation describes a scenario in which goods are supplied along a chain involving three parties, yet those goods are physically delivered from the first party in the chain straight to the last. Each of the three parties must be established, and VAT...

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