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Under the terms of the Withdrawal Agreement and the Protocol, Northern Ireland's VAT rules are to continue to be aligned with those of the European Union in respect of goods. Accordingly, the provisions of Directive 2006/112/EC, arts 20 and 138 etc will continue to apply to the supply and movement of goods between Northern Ireland and the remaining EU bloc (and vice versa). The UK law implementing these provisions of the Directive can be found in VATA 1994, Sch 9ZA, SI 1995/2518 and in certain paragraphs of Notice 725 which have the force of law.

In relation to Northern Ireland, from 1 January 2021, the term 'import' relates only to the arrival of goods in Northern Ireland from places outside the European Union (including Great Britain). Similarly, the term 'export' relates only to the movement of goods from Northern Ireland to places outside the European Union (including Great Britain). Despite Northern Ireland being a part of the sovereign territory of the United Kingdom, for the foreseeable future, it is to be treated