Cross-Border Trading
We act for businesses trading across the Irish border — buying, selling, employing or holding property on both sides — from our office in Castledawson, roughly an hour from the border in most directions.
Cross-border trade is ordinary business here. What is not ordinary is the amount of tax administration attached to it, and the number of businesses running two systems on the assumption that what works in one works in the other.
Where the problems actually arise
Two tax authorities, two sets of rules
HMRC and Revenue are separate, with different filing dates, different thresholds and different expectations. A company trading in both may have obligations in both, and being compliant in one is not a defence in the other.
VAT on goods and services
Under the Windsor Framework, Northern Ireland occupies a distinctive position: it follows EU VAT rules for goods, and UK rules for services. That single sentence causes more confusion than anything else we deal with, because the answer to “do I charge VAT?” genuinely depends on whether you are selling a thing or doing a job.
Registration thresholds differ too. The UK threshold is £90,000 of taxable turnover on a rolling twelve months. The Republic operates separate thresholds for goods and for services, at lower levels. A business trading both sides can be required to register in the Republic while still well below the UK threshold.
Employing people across the border
Someone living in Donegal and working in Derry, or living in Tyrone and working in Monaghan, is a payroll question and a personal tax question at the same time. Which system operates PAYE, where social insurance is due, and whether there is a double taxation position all need answering rather than assuming.
We run payroll in both jurisdictions, which means the ROI side is reported in real time to Revenue under PAYE Modernisation, with PAYE, PRSI and USC rather than PAYE and National Insurance.
Residence and domicile
Where someone is tax resident is a question of fact and statutory tests, not of where they feel they live. It decides what income each country can tax and which reliefs apply. For families with members either side, or people who moved during a tax year, it is worth establishing properly.
Currency
Trading in sterling and euro means exchange differences running through the accounts, and decisions about which currency to invoice in that affect both margin and the VAT position.
What we do
- Accounts and tax returns in both jurisdictions
- VAT registration and returns, UK and Republic of Ireland
- Payroll in both, including cross-border employees
- Residence and double taxation questions for individuals and directors
- Company structure — whether a separate entity is needed in the Republic
- Advice before a transaction rather than after it
Common questions
Do I charge VAT on sales from Northern Ireland to the Republic?
It depends on whether you are supplying goods or services. Under the Windsor Framework, Northern Ireland follows EU VAT rules for goods and UK rules for services, so the two are treated differently. The customer’s VAT status matters as well. This is worth confirming for your specific supplies rather than applying a general rule.
Do I need to register for VAT in the Republic of Ireland?
Possibly, even if you are below the UK threshold. The Republic operates its own registration thresholds, separately for goods and for services, and they are lower than the UK’s £90,000. A business trading on both sides can be required to register in the Republic while remaining below the UK threshold.
Which country’s payroll applies to a cross-border employee?
It depends on where the work is performed and where the employee is resident, and the social insurance position can differ from the income tax position. It should be established at the outset rather than corrected later. We run payroll in both jurisdictions.
Can one accountant deal with both sides?
Yes. We prepare accounts, tax returns, VAT and payroll for both the UK and the Republic of Ireland, which avoids the gap that opens up when two firms each assume the other is handling something.