Invoicing a UK or EU Brand From the US: VAT, Reverse Charge, and What to Put on the Invoice

A brand in London or Berlin wants to sponsor your stream. The deal is agreed, you send your usual invoice, and a day later the brand's finance team writes back: "Can you add our VAT number and a reverse charge note?" Or worse: "Should there be VAT on this?"

If you're a US creator, you've probably never had to think about VAT. The US doesn't have one. But the UK and every EU country do, and a brand's accounts team won't pay an invoice that looks wrong to them.

The good news is that, for the usual sponsorship deal, the answer is simple: you don't charge VAT, and the brand handles it on its side. Here's why, and what to put on the invoice so it gets paid the first time.

The short version

• You usually don't charge UK or EU VAT. When a business buys services from a supplier outside its country, the business accounts for the VAT itself. That's called the reverse charge.
• The brand's VAT number goes on your invoice. It's the brand's evidence that it's a business, which is what makes the reverse charge apply.
• Add a "Reverse charge" note. It tells the brand's finance team who accounts for the VAT, in the words they expect to see.
• Check the number. The UK and the EU both have free online tools for that.
• Not a business? Different rules. Everything here assumes the payer is a company. If an individual is paying you personally, ask an accountant.

Why you don't charge VAT: the B2B rule

VAT depends on where a service is "supplied". For services sold to a business, both the UK and the EU say the service is supplied where the customer is, not where you are.

HMRC puts it in one line: "The B2B general rule for supplies of services is that the supply is made where the customer belongs."¹ The EU's VAT Directive says the same for services sold to a business: "The place of supply of services to a taxable person acting as such shall be the place where that person has established his business."³

So a sponsorship sold to a UK brand is supplied in the UK, and one sold to a German brand is supplied in Germany. But you're not in either country, and that's where the reverse charge comes in.

What the reverse charge means

Normally, the seller charges VAT and pays it to the government. When the seller is abroad, the rules flip it: the buyer works out the VAT and reports it on its own return. The seller charges none.

In the UK. HMRC's notice lists when the reverse charge applies. The place of supply is the UK, "the supplier belongs outside the UK", the customer belongs in the UK, and the supply isn't exempt.¹ It also says what the brand does: "you, the customer, must act as if you are both the supplier and the recipient of the services."¹ For a brand that can reclaim the VAT, HMRC notes, "the reverse charge has no net cost to you."¹

In the EU. The Directive makes the business customer liable: "VAT shall be payable by any taxable person… to whom the services referred to in Article 44 are supplied, if the services are supplied by a taxable person not established within the territory of the Member State."³ The European Commission's plain-English version: "If you receive services for business purposes from a supplier based outside the EU, you should usually pay VAT at the applicable rate in your country… (using the reverse charge procedure)."⁴

In both cases, the brand handles the VAT. You invoice the agreed fee and nothing else.

What if you do an in-person appearance? Showing up at a brand's event in Manchester doesn't change the answer under HMRC's rules. Admission to events has its own rule, but HMRC says "The only B2B service taxable where performed is the admission to an event. All other B2B services are determined under the general B2B rule."¹ You're being paid to appear, not selling tickets, so the general rule still applies.

Don't register for UK VAT "just in case"

Some creators assume that working with UK brands means registering for UK VAT. If all your UK work is sold to businesses under the reverse charge, HMRC says the opposite: "If you only make supplies of services in the UK to which the reverse charge does apply you are not entitled to register for VAT in the UK."¹

And if you put UK VAT on the invoice anyway, the brand can't use it. HMRC tells the customer that it "must still apply the reverse charge as it is not an optional adjustment" and "should advise your supplier to amend or correct their invoice appropriately."¹ Your invoice comes back, and the payment waits.

Why the brand wants its VAT number on your invoice

The reverse charge applies because the customer is a business. The VAT number is how that gets shown. HMRC says that "Unless you have information that suggests the service is wholly for private use, you may presume that your customer is in business if they provide you with their VAT number," and for EU customers, "their VAT registration numbers is the best evidence that your EU customer is in business."¹

The EU's invoice rules point the same way. Article 226 of the VAT Directive lists what an EU VAT invoice has to show. It includes "the customer's VAT identification number… under which the customer received a supply of goods or services in respect of which he is liable for payment of VAT" and, "where the customer is liable for the payment of the VAT, the mention 'Reverse charge'".³

As a US creator you're not issuing an EU VAT invoice, so those rules aren't written for you. But that list is what an EU finance team is used to seeing. Matching it is the easiest way to get your invoice through their review without a back-and-forth.

What to put on the invoice

Start with your usual invoice (here's our free sponsorship invoice template) and add these:

• The brand's full legal name and address. Use the name from its VAT registration, not the product brand you've been talking to. Ask the finance team if you're not sure.
• The brand's VAT number, exactly as the brand gives it to you.
• The total with no VAT line, or a VAT line that says 0, if the brand asks for one. Don't add a VAT percentage.
• A reverse charge note, for example: "Reverse charge: the customer is liable to account for the VAT on this supply."
• The currency you agreed on, stated clearly. If the brand pays in pounds or euros, say so on the invoice. How brands actually pay creators covers keeping conversion and wire fees down.

There's no US VAT number, so leave that field out. If the brand's form asks for one, write "Not applicable (US-based supplier, not VAT registered)."

Check the brand's VAT number

A wrong or made-up VAT number undermines the evidence the reverse charge depends on. It takes a minute to check:

• UK numbers: use gov.uk's Check a UK VAT number service. It shows "if a UK VAT registration number is valid" and "the name and address of the business the number is registered to."² Check that the name matches the company you're invoicing.
• EU numbers: use the European Commission's VIES tool. gov.uk links to it from the same page as "Check an EU VAT number on the VAT Information Exchange System (VIES)".²

Save a screenshot of the result with the deal. If the brand can't give you a VAT number, HMRC says that a customer that can't provide one "or other evidence to clearly demonstrate business activities" should be treated as a consumer.¹ That's a different set of rules, and it's a good time to ask an accountant before you send the invoice.

Watch for the exceptions

Both governments say plainly that the general rules have exceptions. The Commission's page warns, "Be aware that there are several important exceptions to the rules."⁴ HMRC tells suppliers to check "each of the special rules first" before using a general rule.¹

For a normal sponsored stream, ad read or social post sold to a brand, the general business rule is the one that applies. Get advice if your deal is unusual: you're selling to a consumer, the brand is a government body or charity, a UK or EU company of your own is doing the billing, or you're selling goods like merch instead of services.

US taxes still apply

The reverse charge only decides who handles UK or EU VAT. It doesn't change your US taxes. Sponsorship income from a foreign brand is still income. See taxes on sponsorship income for the US side.

A brand outside the US may not send you a 1099, so you may be the only one keeping track of those payments. Log every invoice and payment when it happens, not in April.

FAQ

Do I charge VAT when I invoice a UK brand from the US?
Usually not. For services sold to a business, HMRC treats the service as supplied where the customer belongs, and when the supplier is outside the UK, the UK business accounts for the VAT itself under the reverse charge. You invoice the agreed fee with no VAT added.

What does "reverse charge" mean on an invoice?
It means the customer, not the supplier, is responsible for the VAT. The brand works out the VAT and reports it on its own return. Under the EU VAT Directive, an EU VAT invoice includes the words "Reverse charge" when the customer is liable for the VAT.

Should a US creator register for UK VAT?
Not just for sponsorships sold to UK businesses. HMRC says that if you only make supplies in the UK that fall under the reverse charge, you're not entitled to register for VAT in the UK. Ask an accountant if you also sell to consumers or sell goods.

Why does the brand want its VAT number on my invoice?
The VAT number is the evidence that the brand is a business, which is what makes the reverse charge apply. HMRC calls an EU customer's VAT number the best evidence that it is in business. EU invoice rules also list the customer's VAT number and the "Reverse charge" note.

How do I check a UK or EU VAT number?
For UK numbers, use the free Check a UK VAT number service on gov.uk, which shows whether the number is valid and which business it belongs to. For EU numbers, use the European Commission's VIES tool. Save the result with the deal.