UK VAT Registration Guide for App Developers: When Google Play & App Store Overseas Sales Count Toward (—or Skip) the £90k Threshold

Below is a consolidated, “single-pane-of-glass” wrap-up of everything we have covered about UK VAT registration, how Google Play/App Store revenues fit in, and why the B2B / B2C distinction is critical. Feel free to skim the headings that matter most and keep this as a reference checklist going forward.

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1 | Big-picture timeline

Stage	What you learned	Why it matters
VAT registration basics	Since 1 April 2024 the compulsory VAT registration threshold is £90 000 of UK-taxable turnover in any rolling 12-month window. You must notify HMRC within 30 days of exceeding it. GOV.UK	Establishes the single trigger that drives everything else.
Place-of-supply rules	• B2B services: place of supply = where the customer belongs (the “B2B general rule”). • B2C digital services: place of supply = where the consumer is located. GOV.UKGOV.UK	Determines whether a sale is “made in the UK” and therefore whether it even counts toward that £90 k.
Merchant-of-record model	Your legal customer for Play Store / App Store sales is Google Commerce Ltd (Ireland) or Apple Distribution International Ltd (Ireland). That is a B2B supply of digital services to a non-UK business.	Means the place of supply is Ireland → outside the scope of UK VAT → excluded from the £90 k test.
Practical upshot	Unless you have another stream of UK-sited turnover (direct UK consumer sales, UK consulting etc.) above the threshold, HMRC will not require you to register yet.	Explains why the sizeable GBP payouts you see in your bank do not, on their own, push you over the line.

2 | How to measure the threshold correctly

1. Start with your total revenue.
2. Strip out anything whose place of supply is outside the UK.
   • This includes the Google/Apple receipts because they are B2B services supplied in Ireland.
3. Result = UK-taxable turnover.
4. Maintain two running totals (updated each month):
   • UK-taxable turnover over the last 12 months.
   • Forecast UK-taxable turnover for the next 30 days (HMRC’s future-looking test).
5. Only the first figure must stay below £90 000 to avoid compulsory registration.

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3 | Why B2B vs B2C flips the place-of-supply outcome

Scenario (digital product)	Customer status	Place of supply rule applied	Included in £90 k?
Google/Apple acts as merchant, you invoice their Irish entity	B2B	Customer in Ireland ⟹ supply made in Ireland	No
Direct sale of coins from your own site to a gamer in London	B2C	Consumer in UK ⟹ supply made in UK	Yes
Direct subscription sale to a business in Germany	B2B	Customer in Germany ⟹ supply in Germany	No
In-app purchase by a gamer in California via Stripe	B2C	Consumer in USA ⟹ supply outside UK	No

Key insight: The currency (GBP vs USD) and the bank account (Google Ireland paying a UK IBAN) are irrelevant for VAT. HMRC looks solely at who the customer is and where they “belong”.

4 | Options if you approach the threshold

Path	What it means	Pros	Cons / risks
Do nothing until you actually exceed £90 k	Keep monitoring UK-taxable turnover monthly.	No admin burden until you have to.	If you mis-count and go over, HMRC can backdate VAT plus penalties.
Apply for the “registration exception”	If you breach the limit only because of a one-off UK contract you expect not to repeat.	Lets you stay unregistered.	HMRC rarely grants it without solid evidence.
Voluntary registration	Register even below the limit to reclaim input VAT on UK costs (marketing, hosting, SaaS).	Potential net VAT refunds each quarter.	Quarterly filings; must add 20 % VAT to any UK consumer sales.
Artificial split of businesses	Move UK sales to a second entity to keep each under £90 k.	Appears to delay registration.	HMRC can aggregate entities it deems artificially separated → back-tax + penalties.

5 | Record-keeping & compliance checklist

1. Google / Apple self-billing statements – archive monthly PDFs; they show the Irish VAT number proving the B2B status.
2. Turnover tracker spreadsheet – one column for UK-taxable turnover, one for overseas/out-of-scope.
3. Contracts & invoices – clearly identify customer names, addresses and VAT numbers for B2B deals.
4. Marketing & SaaS invoices – keep VAT invoices if you plan to reclaim input tax upon voluntary registration.
5. Forecast tool – alert if projected UK-taxable turnover exceeds ~£80 k so you have 30 days to act.

6 | Frequently-asked “edge-case” clarifications

• Payouts in GBP from Ireland – still outside UK scope; currency does not override place-of-supply.
• UK users buying via Apple / Google – Apple/Google handle consumer VAT themselves; you remain outside scope.
• Direct sales to EU consumers – outside UK VAT, but you may need a Non-Union One-Stop-Shop (OSS) registration to remit EU VAT.
• Reverse-charge entries – if you do register, you will put Google/Apple receipts in Box 1 (reverse charge) and reclaim the same amount in Box 4, netting to zero. The sale remains outside Box 6.

7 | Action plan for the next 12 months

1. Implement the turnover tracker this week.
2. Audit all revenue streams to confirm which are truly UK-sited.
3. Decide on voluntary vs compulsory path once UK-taxable turnover hits ~£75–£80 k.
4. Prepare Making-Tax-Digital (MTD) software early if you anticipate registration – the lead time for integrations can be months.
5. Review EU & US tax angles (OSS, state sales-tax, IRS Form 1042-S) with a cross-border tax adviser.

8 | Key take-aways

• The £90 000 threshold applies only to supplies made in the UK.
• Google/Apple revenues are B2B, place of supply Ireland, hence outside the scope and ignored in that test.
• The B2B vs B2C label is decisive because it flips the place-of-supply rule for services.
• Track UK-taxable turnover rigorously; HMRC can backdate VAT and add penalties if you get it wrong.
• Voluntary registration can be cash-positive if your input VAT on UK costs is material and your sales remain largely outside scope.

In short: Your app-store income, although substantial, does not currently require UK VAT registration because it is legally a B2B export of digital services to Ireland. Only when the UK-sited, UK-taxable slice of your turnover exceeds £90 k in a 12-month window does compulsory registration kick in. Maintain clear records, monitor the UK figure monthly and you will stay on the right side of HMRC.