While the trade deal between the EU and UK is still far from clear as of November 2020, there is certainty around tax changes that are happening on 1 January 2021. 

On 31 January 2020 the UK left the EU and entered into an 11-month transition period. 

From 1 January 2021 the UK will no longer be in the EU customs union and single market. 

VAT – Republic of Ireland and Northern Ireland 

Northern Ireland (NI) will remain part of the UK VAT regime but EU VAT rules for goods will continue to apply. Therefore, from 1 January 2021 the current VAT treatment should continue to apply to trade in goods between Republic of Ireland (ROI) and NI. 

However, the position regarding services is different. UK VAT rules apply to NI services provided to EU customers.

VAT – Republic of Ireland and Great Britain 

Sales of goods from ROI to GB will be treated as exports from Ireland and will fall to be Zero rated for VAT. The responsibility for UK VAT will fall on the UK importer. 

UK imports of goods will be subject Irish VAT at point of import. This VAT will be the liability of the importer. The Irish Government has stated that it will introduce postponed accounting for VAT on imports carried by Irish VAT registered businesses in the event of a no-deal Brexit. 

Customs – Republic of Ireland and Northern Ireland 

EU customs rules will continue to apply to NI, so no customs controls, declarations or tariffs will be required for the movement of goods between NI and ROI. 


Customs – Republic of Ireland and Great Britain 

From 1 January 2021 customs duties will apply on goods traded between GB and ROI (and the EU) Unless a Free Trade Agreement (FTA) is reached between the UK and the EU.  

If an FTA is reached between the UK and the EU, reduced or zero tariffs will apply to goods that are of UK or Irish/EU origin. 

Where an FTA is not reached between the UK and the EU: 

  • Any goods imported into GB from ROI will be subject to the UK’s new Global Tariff schedule 
  • Any goods imported into ROI from GB will be subject to the EU’S Common External Tariff 

The UK Government plan to introduce customs controls on goods arriving from Ireland/EU on a phased basis up to 30 June 2021. 

The EU have declared that normal customs procedures will apply from 1 January 2021, to goods being imported into the EU. 

Brexit Actions which businesses need to urgently consider 

1. Review your supply chain and understand the potential impact 

2. Review contracts to see if change is required 

3. Apply to Revenue and HMRC for an EORI number, this is required to operate within the customs    regime 

4. Clarify rates of Customs Duty applicable to your goods (CN Code) 

5. Who will file customs declarations (inhouse or customs agent) 

6. Identify any customs authorisations or simplifications that apply 

7. Understand your obligations under HMRC rules (UK) 

8. Understand your obligations under the Irish (EU) rules 


Without doubt, the Brexit changes coming on 1 January 2021 will impose extra administration and cost on businesses. This is a fact, regardless of what agreement, if any, is concluded between the EU and the UK. However, by acting now administrative time and costs can be greatly reduced. 

Key Contacts 

Gordon Hayden      ghayden@cooneycarey.ie 

Gerry Higgins          ghiggins@cooneycarey.ie 

Eamonn Madden   emadden@cooneycarey.ie 

Gillian Conway       gconway@cooneycarey.ie