The appellant, based in the Channel Islands, sold non-prescription health products to retail customers, who placed orders by phone, by internet or by post. Most of the goods were delivered by post, but some were delivered by courier. The overwhelming majority of the appellant’s products were dispatched from a warehouse in the Netherlands and delivered to customers in the UK.
The appellant originally sold goods from the Channel Islands and took advantage of the Low Value Consignment Relief so that VAT was not charged on the supplies. When this relief was withdrawn the appellant decided to relocate to the Netherlands and use a fulfilment house, PostDirect, to store and despatch the goods. The appellant contracted directly with PostDirect to dispatch the goods which sold at a single price of delivered goods.
HMRC decided:
- that during the relevant period the goods had been delivered “by or on
