Why VAT thresholds matter
The moment your taxable turnover crosses a registration threshold you are legally required to register, charge VAT and file regular returns. Registering late — or failing to register at all — results in penalties and backdated VAT liability calculated from the date you should have registered, not the date you actually did.
Each country sets its own threshold and the rules differ significantly.
United Kingdom
The UK VAT registration threshold is currently £90,000 of taxable turnover in any rolling 12-month period — one of the highest in Europe.
- Mandatory registration — you must notify HMRC within 30 days of the end of the month in which you crossed the threshold
- Voluntary registration — you can register below the threshold to reclaim input VAT on business purchases
- Deregistration threshold — if taxable turnover falls and is expected to stay below £88,000, you may deregister
- MTD for VAT — all VAT-registered businesses must file returns through MTD-compatible software
Once registered, most businesses file quarterly returns via Making Tax Digital. Monthly returns are available if you regularly receive VAT repayments.
France
France uses a two-tier system based on business type:
| Business type | Franchise en base (no TVA) | Régime réel simplifié |
|---|---|---|
| Sales of goods | Up to €91,900 | €91,900–840,000 |
| Services / liberal professions | Up to €36,800 | €36,800–254,000 |
Businesses below the *franchise en base de TVA* threshold neither charge TVA nor reclaim input tax. They write *TVA non applicable — art. 293B du CGI* on invoices.
Once above the threshold, TVA declarations are filed monthly (régime réel normal) or quarterly (régime simplifié) via DGFiP.
Germany
Germany has the *Kleinunternehmerregelung* (small business rule) under §19 UStG:
- Previous-year turnover below €22,000 and current-year expected turnover below €50,000 → you may opt out of VAT entirely
- Once you exceed €22,000 in any calendar year, you must register for full VAT from 1 January of the following year
- Standard rate (Umsatzsteuer) is 19%; reduced rate is 7% for food, books and selected services
German VAT returns — *Umsatzsteuer-Voranmeldung* (UStVA) — are filed monthly or quarterly via ELSTER, with an annual *Umsatzsteuerjahreserklärung*.
Registering in multiple countries
If you sell to customers across the UK, France and Germany, you may need to register in more than one jurisdiction. Key triggers:
- UK — taxable UK sales exceed £90,000
- France or Germany — you have a fixed establishment (office, warehouse, employees) in the country
- EU VAT OSS — if you sell digital services or goods to EU consumers above €10,000/year across all EU member states, the One Stop Shop lets you report all EU VAT in a single return filed in your home country
How Finovo tracks your threshold exposure
Finovo monitors your rolling taxable turnover per jurisdiction and highlights when you are approaching a registration threshold. Need to work out VAT on a single invoice in the meantime? Use our free VAT calculator. Once registered, it handles MTD submissions to HMRC, TVA declarations to DGFiP and UStVA filings to ELSTER — from the same ledger, with no duplicate data entry. See pricing →