In short, after Brexit, businesses based in Great Britain (England, Scotland, and Wales) can no longer apply the reverse charge to EU sales. However, businesses based in Northern Ireland can still apply the reverse charge as normal because they are still within the EU VAT area.

EU countries often have very low or no registration limit for non-EU businesses, so the import and onward sale of goods either in the UK or any EU member state is likely to give rise to a requirement to register for VAT.

This requirement is driven by who 'imports' the goods - the contract or Inco-terms will help define that. So in the case of Delivery Duty Paid (DDP) the supplier is the importer, and that in the case of Delivered At Place (DAP), the customer is the importer.

When shipped via DAP, the business customer in the relevant EU member state self-accounts for VAT under the 'reverse charge' mechanism via their VAT return in as much the same way as if they were importing goods from China or the US.