I work for an organisation that can afford to build the IT system required and we are still struggling. we are also stuck on proof of customer location where billing and IP countries conflict. our tax advisers have said customer certification won’t be classed as proof so we are considering using country code of telephone number, which is probably just as bad. we’ll collect the 3 and only proceed with EU customers who provide matching evidence for 2. Non of the presumptions apply to us, our tax advisers can’t suggest any other evidence and our payment company can’t provide any information until after the sales.