Attempting to get Live for Speed enrolled for MOSS to comply with new EU VAT rules.

First time we heard of MOSS

First learned about MOSS, from our part time web developer, who overheard colleagues at his full time job talking about it.
Decided to deregister for VAT, as we have been below the UK VAT threshold for years. At first this seemed a good idea. Went ahead and requested deregistration.
Further research showed us that there is no threshold for EU VAT under the new rules, and a UK VAT number is required in order to use MOSS, so our previous action seemed to be a mistake. We phoned Gary on VAT helpline. He referred us to the VAT deregistration team (03000523234). Tried to contact them but didn't get through that day.

We phoned VAT deregistration team, talked to Alison of Team B. Our deregistration request was removed, so all back to normal.



Gathering information

Researched further, including this page "Register for and use the VAT Mini One Stop Shop":
(see screenshots info_moss_1.gif and info_moss_2.gif)

Also the government page "Policy paper - Revenue and Customs Brief 46 (2014): VAT rule change and the VAT Mini One Stop Shop - additional guidance"

It seems that we need to do two things:
1) register for MOSS
2) set our "Business Activity" to ‘Supplies of Digital Services’ (below UK VAT threshold) under MOSS arrangements

Phoned VAT helpline (03002003701) and got through to Stephen. Call reference CGV48952. He did not know that you could be registered for VAT but not pay UK VAT under the new rules recently confirmed by the government. We directed him to the Brief 46 page but he suggested that we should talk to a person from a technical department. He would put our number through to them and said they would probably phone us the next day. But this never happened.



Attempting to sign up

As we had not got a reply from the technical department, we decided to simply try to register for MOSS. Our thought was that maybe on registering, we would be able to set our "Business Activity" to ‘Supplies of Digital Services’ (below UK VAT threshold) under MOSS arrangements.

We then got the same thing that has always happened when we try to enrol for MOSS. When logged in at HMRC, we find the page "Enrol for VAT Mini One Stop Shop (MOSS)". We enter 01/01/2015 and our VAT number, then submit. We then get this message: "ERROR: The details you have entered are either incorrect or you may have already enrolled for this service. If the problem persists please contact the HM Revenue & Customs Online Services Helpdesk or select 'Back' to return to Your Services."
(see screenshots moss_enrol_1.gif and moss_enrol_2.gif)

We then contacted the Online Services Helpdesk (using a web form) as suggested, describing the problem. They sent an email saying "Suppliers must first register for VAT MOSS in the UK" (spam_email_1.gif) and some more info which of course we already knew, having studied the site for days. We replied by email to their email but this was rejected. We used the web form again and this time we got a reply "You have submitted your query to the VAT Online Services Helpdesk and not the VAT written enquiry team." (spam_email_2.gif). Although this didn't seem a good idea, as we were reporting an apparent website error, we did as we were told and contacted the written enquiry team. Our email was auto-confirmed as received but we have never received a reply to it.



Getting nowhere

Decided to write again to the Online Services Helpdesk, using the page "Question About An Online Service" explaining clearly that it seems to be a website issue, and describing the issue exactly. The response was exactly the same as on the 22nd: "You have submitted your query to the VAT Online Services Helpdesk" (as seen in spam_email_2.gif).

It seemed we were not getting anywhere. You can wait half an hour on the phone, and get through to someone who doesn't know the answer. The website people just paste random meaningless info, or nothing at all. So we decided it would be simpler to deregister for VAT, then re-register for VAT and MOSS with "Business Activity" set to ‘Supplies of Digital Services’ (below UK VAT threshold) under MOSS arrangements. Maybe it would work, for a new account, as it seemed hopeless trying to set our existing account to this status.


Not allowed to deregister for VAT

We looked into our account online to see if there was any progress with our de-registration. We found a message dated 29/12/2014 rejecting our application to deregister for VAT. This was surprising as we have traded below the threshold for around 3 years. There is no explanation for the decision but they say you can contact them if there is more information for them to consider (and there is a reference number).
(see screenshot vat_deregister_fail.gif)

We obviously wrote using the appropriate web form explaining our situation, hoping for an explanation. But our email was rejected with the text "Thank you for your submission dated 31/12/14. Unfortunately we are unable to progress your application because you have failed to enter the correct reference number given to you when the request for further information was made." There was a phone number in the email which we tried to call but the number was not recognised (01902 392000).


New Year

Now that we are in the correct year, we tried again to enrol for MOSS on the page "Enrol for VAT Mini One Stop Shop (MOSS)" as described above in the section 22/12/2014. The same error message appeared.
Again we wrote to the Online Services Helpdesk, really trying to keep the message as simple as possible.

In response to yesterday's helpdesk request, once again we received the copy and paste of vaguely related information (spam_email_1.gif). So we tweeted to @HMRCcustomers. They asked us to send them some info and would look into it for us. We did so and they asked us if we had double checked the information we entered. We have told them it was just a date and a VAT number, not much to go wrong.

We are now writing tweets from our account @LFSracing and asking on facebook page to see if anyone else has successfully registered, and if so, how they did it.
We were advised by one user to try using the government gateway website instead of HMRC. This did not work either and the result is shown in the screenshot gov_gateway.gif
(see screenshot gov_gateway.gif)

Communicating with HMRC

Twitter service @HMRCcustomers had offered to help on Friday, so we got our info together on this web page and sent them a link to it. But now they seem to have changed their mind and simply ignore us completely.

We tried a few things suggested by people on Facebook. Nothing worked. The HMRC page takes us round and round in circles. The sequence goes like this:

Clicking "Your HMRC services" takes us to "Your tax account BETA" page. There we can click "registering for taxes" and on the next page we can click "Register for VAT MOSS". At that point it asks us to log in again (although we were already logged in) and that takes us straight back to "Your tax account BETA" page. At this point we have gone in a circle, so we try something different: "Enrol for other services" and then we try to enrol for MOSS and that always fails as shown in image moss_enrol_2.gif.

Phoned the VAT helpline. After some waiting, got through to Tom. Call reference CFB45150. He tried to go through the MOSS registration process with us. It went in the circle described above. He said this is probably the problem. He isn't familiar with that BETA page and said we shouldn't be seeing it - our page looks more like a personal account page. I have some doubt about this as it does mention "Self Assessment Online for Partnerships".

Anyway, if we need to create a new online account that's fine but there is still the nagging problem of our VAT status. We are currently VAT registered, due to previously trading above the VAT registration limit. But our combined EU+UK sales have been well below the deregistration limit for 3 years. With hindsight we should have deregistered 3 years ago, but there was a chance our UK+EU sales could have exceeded the limit at some point. Under the new rules for digital services, the deregistration limit is now based on our UK sales only (because non-UK EU VAT is paid through the MOSS system). Our UK sales will be so far below the deregistration limit, there is no chance of exceeding it. So, with our UK sales at around £10k, it is important not to continue paying UK VAT.

But we have not been able to find any way to convert our existing VAT registration to the new status "supplies of digital services (below UK VAT threshold) under MOSS arrangements". No-one we have spoken to knows how this could be done. Tom suggested we may need to deregister for VAT and then take it from there (including re-registering for VAT as soon as we have deregistered). We have tried this before and our request was rejected. He then put me through to the deregistration team and I talked to a woman there. I asked why our deregistration had been rejected. She explained that because our "total sales" had been above the limit, their computer had rejected our application to deregister. The problem is, our total sales are not actually relevant to the decision, because they specifically include ALL our sales, including the ones outside the EU. [VAT Notice 700/12, Section 3.7] Apparently this cannot be sorted out over the phone and we need to write to them. I explained that their website did not allow us to reply to their original rejection. She gave me a new reference number. She also said she would ask someone in a technical team to contact us.

Using this, we sent a new email with more information and that seems to have gone through. Hopefully in the light of the new information, they will be able to process our deregistration.

Later we received an email from Sunita of "MNR Team". She told us that she had tried the phone number they had for us but it didn't work (although it has not changed for over 6 years) and wrote "I advise you not to apply for de-registration but to go online & apply for Moss under the Union Scheme." This was too late as we had already sent more information to enable our deregistration. Anyway, it appeared she didn't have full knowledge of our situation. The good thing is it was a proper email with a real email address that we could reply to! This was the first time that we could reply to someone who had written to us! We replied to her with more info, describing our problem and providing a link to this blog.

Managed to submit a MOSS application!

Some good news today because one of our main two problems seems to have been solved. This morning we received an email from John in "MOSS and NETP Registration" (I guess that is the same as MNR Team) who had picked up our reply to Sunita and wrote "I'm investigating to see if there is a simple solution with your existing registration". This afternoon we got a phone call from Gillian who was very helpful and talked us through submitting a MOSS registration.

We have described the (illogical) sequence of clicks that allowed us to successfully submit an application for MOSS registration, on this page:

She and others are continuing to look into our other problem (related to VAT thresholds, described above) and she should phone back today or tomorrow. We pointed out that we had already sent more info to the VAT deregistration team, which might cause a conflict if we were in fact able to keep our existing registration.

MOSS Registration Approved

Got a message in "Your messages" section of the HMRC site. "HM Revenue & Customs can confirm your request to register for the VAT Mini One Stop Shop (MOSS) has been approved. Your registration will take effect from 01/01/15."

We are expecting another call later today to let us know the progress on setting our "Business activity" to ‘Supplies of Digital Services’ (below UK VAT threshold) under MOSS arrangements.

We did not get the expected call.


Confirmation that we no longer have to account for UK VAT

Sent an email to John, saying that we had expected to hear from Gillian the day before. We pointed out that we are a micro business with UK sales of around £10k per year, very far below the threshold. We explained that our understanding is that our "Business activity" needs to be changed from:
> Other information technology service activities
to this new option:
> ‘Supplies of Digital Services’ (below UK VAT threshold) under MOSS arrangements

We got an email from John a little later with the following information:

"Regarding your VAT threshold, I'm waiting to hear back if we need to change any of your records. As VAT is essentially self-regulated, you should be able to stop accounting for UK VAT on your domestic VAT returns as you fall under the threshold given the allowance for micro-businesses.

The business activity description: "Supply of Digital Services" (below UK VAT threshold) under MOSS arrangements, was set up simply to allow us to identify the new VAT registration applications that we're now receiving from micro businesses. It doesn't have any significance beyond the point of registration when it comes to submitting returns."

We replied back to request confirmation that our deregistration attempt had been stopped, as it was not needed any more and might cause a problem if it went through. John replied that it had already been stopped on Wednesday.

Gillian also phoned, apologised for not getting back to us the day before. Other things had come up. She confirmed what John had told us in his email, and that we should enter zero in the boxes on our future UK VAT returns. We pointed out an error on the website that does not allow us to see our MOSS registration from the "Your tax account BETA" page. We can see that we are enrolled for that service if we click the link in the "Stop using an online service" section. She was unable to help us with this, and referred us to a link at the bottom of that page where we should be able to get the message through to the relevant team.

Later John emailed once more to say that he has amended the business activity on our VAT registration to: 63990 Other Information Services Activity.

We confirm that when we look online at our VAT registration certificate, we see:
Business activity description: Other information service activities n.e.c.

This is not quite as we expected but doesn't seem to be an issue.

End of story?

It seems we are registered for MOSS and we have our exemption from UK VAT. Although grateful for the help from John and Gillian, we have been quite shocked by how difficult this has been and how long it has taken to make these simple adjustments to our account.

It was very hard to get in touch with anyone who can see the full picture at HMRC. It seems that most people only understand their own department in a narrow and limited way. Once we were promised a call back from a technical department, but the call never came. We were given false advice on the helpline. We were advised that we might have to delete our online account and make a new one. The suggestion was made that we might need to deregister for VAT and register again. Neither of these were necessary. HMRC should be ashamed of their "Online Services Helpdesk" whose only function seemed to be to copy and paste random text, or attempt to refer you to other departments without any explanation.

It seems clear that HMRC have not properly tested the MOSS registration systems on their website. Misleading error messages, links that take you round in circles on the website, failure to display a link to the MOSS section from the home page, and staff who don't know any better. The time taken to try to get through all these problems, just in order to comply with new EU laws that have not been thought through properly, is not acceptable.