Agents could be fined up to £1,500 if they fail to comply with the new EU ‘place of supply’ rules which came into play on January 1.
The rules mean agents who contract direct with hotels or other suppliers overseas and are given a commission must submit an EC sales list each quarter setting out the total commission earned from each hotel or supplier.
Agents should already be collecting clients’ VAT numbers for use on the sales list, said David Bennett, VAT partner at accountants Saffery Champness.

“Every agent has to start doing a sales list,” he said.

“I spoke to a room of travel agents recently but many had never heard of it.
“This is a legal requirement. HM Revenue & Customs (HMRC) have said it will take a light touch, but not for long. In extreme circumstances, HMRC could impose a £1,500 fine for every missing list.”
Bennett said it was “no easy task” to set up the systems to create a sales list.
He added: “You must be an agency earning commission to do this, not a principal adding a mark-up.”
Meanwhile, the EU is considering a review of the Tour Operators’ Margin Scheme. A meeting of the member states was held on February 3 and Bennett said discussions were “positive”.
Spain currently holds the EU presidency, but all member states must vote in favour before the review can go ahead.
Bennett said: “They want to get rid of all the problems and inconsistencies and have committed to another meeting, probably in April.”