Like many, I’ve only recently discovered this ‘by accident’. As I was planning to sell digital products to non-VAT registered businesses the new rules would apply to me.
Because they wouldn’t be able to supply me with a VRN, I checked out HMRC’s website re: “alternative evidence of business status”. HMRC says:
“If a customer claims to be in business but not to be VAT registered then alternative evidence should be obtained. This can be in the form of other reasonable commercial evidence or records that should normally be available, for example contracts, business letterheads, a commercial website address, publicity material, certificates from fiscal authorities, and so on. A digital certificate from a reputable organisation can also be used for this purpose.” (VATPOSS05620)
The logical choice for me is to ask for a commercial website address.
However, if I have “any reason to believe that [such evidence] is false or is being used incorrectly”, I am required to carry out a “full verification”.
If I sell my products online with automatic download, can anyone explain how I can become aware of “any reason” or how I can undertake such “full verification” prior to completing the transaction?