How to Register for VAT in Ireland: A Guide for Companies

A company expanding into the EU registers for VAT in Ireland by one of two routes, and the route decides the rules. An Irish-incorporated company applies online through Revenue Online Service on Form TR2, and registers once turnover passes €85,000 for goods or €42,500 for services. A non-established company has no threshold at all. It applies on paper, using Form TR2(FT), and must be registered before its first taxable supply.

Almost everything published on Irish VAT registration covers the first case and skips the second. That’s the wrong emphasis for a company headquartered in Boston or Birmingham, because the second case is usually the one that applies first.

Do I Need to Register for VAT?

Do You Need an Irish VAT Number at All?

It's important to understand the requirements for registering for Vat and many companies register when they didn’t have to, and then carry the filing obligation for years.

For business-to-business services, the place of supply is where the customer is established. The Irish customer self-accounts for the VAT under the reverse charge, and the supplier charges nothing. A US software company invoicing an Irish plc, or a UK consultancy billing a Dublin bank, generally has no Irish registration obligation at all. Revenue sets this out on its page for non-established traders.

The exceptions are what matter. A non-established trader is a business that makes taxable supplies in Ireland but does not have a fixed establishment in the State. This includes many UK, US and other overseas companies that import goods, hold stock or make local supplies in Ireland. Revenue lists the situations where a non-established trader has to register regardless of turnover, and several of them describe exactly what a company does when it starts selling into the EU properly.

The moment stock lands in an Irish warehouse, or goods clear customs at Dublin Port in the company’s own name, the registration obligation exists with the turnover being irrelevant.

For a company that has incorporated an Irish subsidiary, the thresholds do apply. Revenue’s current figures are €85,000 for a business supplying goods, €42,500 for a business supplying services only, and €85,000 where a business supplies both and at least 90% of turnover comes from goods. There’s a separate €41,000 threshold for persons registering solely because of intra-Community acquisitions, and a €10,000 EU-wide threshold for distance selling and cross-border telecoms, broadcasting and electronic services.

Most companies in this position register voluntarily well before they hit any of those numbers, because without a VAT number they can’t recover Irish VAT on set-up costs, and their EU customers can’t zero-rate supplies to them.

Ireland’s €85,000 and €42,500 VAT thresholds apply only to businesses established in the State. A non-established company has no threshold, and must be registered before it makes its first taxable supply in Ireland.

If your model is direct-to-consumer across multiple Member States, the answer may not be an Irish VAT registration at all, or not the only one. The One Stop Shop (OSS) and Import One Stop Shop (IOSS) let you account for VAT on B2C sales across the EU through a single return. We cover how this works for business and how to register for IOSS in our guide to IOSS registration in Ireland.

Domestic-only or Intra-EU, and why it matters for VAT Registration

Since June 2019, Ireland has run a two-tier VAT registration system. Every applicant has to say which tier they want, and the two are not interchangeable.

Domestic-only exists to give genuinely local businesses a faster registration, and to keep missing-trader fraud out of the intra-Community system. It works perfectly well for a company selling into Ireland and to the rest of the world. It does not work for a company using Ireland as its EU base, because without Intra-EU status you cannot make intra-Community acquisitions, and the whole point of an Irish entity for most of this audience is to buy and sell inside the single market.

Revenue is explicit that Domestic-only customers can apply for Intra-EU status at any time. In practice, applying for the tier you actually need at the outset is faster than registering on the easier tier and upgrading three months later under commercial pressure, because the second application asks for the same evidence the first one would have.

Domestic-only VAT registration covers trade within Ireland and with non-EU countries. It does not permit intra-Community acquisitions, which makes it the wrong registration for any company using Ireland as its EU base.

What Revenue Needs for VAT Registration from Foreign-owned Companies

Applications stall here more often than anywhere else, and it’s the part of the process that published guidance handles worst.

For Intra-EU status, Revenue requires additional information on the application: the type of customer you’ll supply, the due diligence you conduct on current and prospective EU suppliers, how goods are supplied outside the State, an estimate of annual and quarterly supply, turnover for the previous calendar year, turnover for the current year to date, and evidence of trade or substantive evidence of intention to trade with other Member States. The examples Revenue gives are invoices, contracts, leases and detailed business plans.

Almost every item is a test of whether the business is real and whether the Irish activity is real. A newly incorporated Irish subsidiary of a foreign parent, with the following situations satisfies none of them:

• No Irish-resident director;
• No trading history;
• No Irish address beyond a registered office;
• No commercial rationale for the Irish company;
• Transactions only with group companies;
• Insufficient evidence of intended EU trade

We’ve handled hundreds of these applications, and the pattern is consistent. Registrations move faster when the file shows a mix of Irish customers and Irish suppliers rather than transactions exclusively with the parent, a one-page business plan that explains what the Irish company will actually do, an Irish phone number, an .ie domain, and in some cases a short-term lease or co-working agreement at an address that isn’t just a service address. None of that is a legal requirement. All of it changes how the application reads.

The applications that get queried are the ones where the evidence pack is thin and the follow-up letter from Revenue lands in a foreign head office where nobody knows what to do with it. If you have no Irish presence to field that correspondence, put one in place before you apply. Nathan Trust’s VAT registration team prepares the evidence pack and acts as the Irish point of contact for Revenue’s queries, which is usually where the time is won or lost.

How to Apply for VAT: Forms, Routes & the Paper Trap

The mechanics diverge sharply depending on whether you’re established in the State of Ireland.

Revenue restricts ROS eRegistration to businesses established in the State. A non-established company cannot use it. It completes the paper TR2(FT) and posts it to Wexford, which surprises most people encountering the Irish system for the first time, and which sets the tone for the correspondence that follows.

The rule runs in both directions. Revenue returns paper applications from businesses that could have applied online, with a request to do it through ROS. Sending the wrong form on the wrong channel costs weeks and puts you back at the start of the queue.

One point on cost: Revenue publishes no service standard for VAT registration, and anyone quoting you a fixed number of weeks is guessing. What actually determines the timeline is whether the evidence is complete on first submission and whether the case officer raises a query.

Timelines when Registering for VAT

Registration generally takes effect from the date stated on your application form, but Revenue can agree to backdate it. When you’re registering electively rather than because you’ve crossed a threshold, the effective date cannot be earlier than the start of the taxable period in which you apply.

The point that catches companies out is what happens in between. Your VAT liability runs from the date registration became obligatory, not from the date the number appears in your inbox. Trading while an application is pending doesn’t suspend the obligation; it just means you’re accruing VAT you haven’t collected, on invoices you’ll need to correct.

VAT liability runs from the date registration became obligatory, not the date Revenue issues the number. A company that trades while its application is pending still owes the VAT on those supplies.

There are workable ways to handle invoicing during that window, and they’re much easier to implement before the first invoice goes out than after. Get the sequencing right at the planning stage.

One ongoing obligation starts immediately. If any of the information you have submitted to Revenue changes, from directors to business address to the nature of the activity, you have 30 days to tell them.

What to file after you're Registered for VAT

The compliance load in Ireland is moderate by EU standards, and it’s worth sizing before you commit.

The standard taxable period is two months, beginning 1 January, March, May, July, September and November. Monthly returns are available on request and are usually granted to traders in a constant repayment position, which describes a lot of export-led businesses. Once you’re registered, filing and payment are electronic through ROS, with no paper option.

The VIES obligation follows automatically from Intra-EU status, and it applies regardless of value. If you zero-rate a single supply to a VAT-registered business in another Member State, it goes on a VIES statement. Intrastat is a separate statistical regime and only bites above €750,000 of arrivals or dispatches a year, though every registered trader completes boxes E1 and E2 on the VAT3 return.

Two cash-flow mechanisms are worth knowing about once you’re registered, though neither forms part of registration itself. Postponed accounting lets you account for import VAT on the VAT3 return instead of paying it at the border, which matters if you’re bringing goods in from Great Britain or anywhere else outside the EU. And traders deriving at least 75% of turnover from exports or intra-Community supplies of goods can apply on Form VAT 56A for a Section 56 authorisation, which lets them receive most goods and services at the zero rate. Both are separate applications made after registration, and both are covered in their own guides.

Working with Nathan Trust to Get VAT Registered

We register companies for Irish VAT as part of the work we’ve done for international clients since 1999, and we do it end to end.

That means preparing and filing the TR2 or TR2(FT), assembling the evidence pack Revenue expects for Intra-EU status, acting as the Irish point of contact for any query the case officer raises, and setting up the ROS filing cycle once the number issues so the first VAT3 return doesn’t arrive as a surprise. Where the right answer is that you don’t need an Irish registration, we’ll tell you that too.

Engagement starts with a call to establish what you’re actually supplying, to whom, and from where, because those three answers determine everything above. Talk to our VAT registration team and we’ll tell you which route applies and what it takes to get there.