Updated October 2026: the EU distance-selling thresholds, Apple's EU entity and the Google Play position have been corrected to reflect the current rules.
Selling apps abroad is complex because VAT on digital services sold to consumers is due where the customer lives, not where you are. Since 1 January 2021, a UK business selling digital services such as apps, in-app content or downloads directly to consumers in the EU has no threshold: EU VAT is due from the first sale. You either register for the EU's non-Union One Stop Shop (OSS, which replaced the non-Union MOSS on 1 July 2021) in one EU country, or register for VAT in each EU country where you have customers. The old €35,000 and €100,000 distance-selling thresholds were abolished on 1 July 2021. Selling direct also means identifying where each customer lives and keeping evidence of it. The good news is that if you sell through an app store, the store is normally treated as the supplier to the consumer and accounts for the VAT instead of you (GOV.UK). Here is how the main platforms work:
Apple AppStore
You supply your apps to Apple, who then markets and sells them to consumers and charges VAT based on the customer's location. For EU storefronts, Apple Distribution International Ltd in Cork, Ireland acts as Apple's commissionaire for developers based outside the EU (Apple Developer). Apple, as the platform, accounts for the VAT on the sale to the consumer. Your own supply is to Apple, so it is a business-to-business supply: where the Apple company you supply belongs outside the UK, such as the Irish company, it is outside the scope of UK VAT. Since 1 January 2021 you no longer complete an EC Sales List for services supplied to EU businesses. As with many things Apple, this model is very slick!
Google Play
This is where things have changed most since this article was first written. Back then, the sale was treated as being between the developer and the end customer, so the developer had to collect the right VAT for each customer's location. Today, for paid apps and in-app purchases using Google Play's billing system, Google is the merchant of record for customers in the UK and the EU/EEA. Google works out, charges, collects and pays the VAT to the tax authorities, so you don't account for VAT on those sales separately (Play Console Help). If you use an alternative billing system where Google allows it, you become the merchant of record and the VAT is yours to handle.
Other stores
Check each store's terms to see who is the merchant of record. If the store sets the terms, takes the payment or delivers the download, it is normally treated as the supplier and accounts for the VAT. If you sell direct from your own website or through alternative billing, the VAT is your responsibility. Note that Amazon closed its Appstore on non-Amazon Android devices on 20 August 2025; it remains available on Fire TV and Fire tablets.
