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In addition to the requirements laid down in the Exporting goods ― overview guidance note, businesses intending to zero-rate exported goods must hold satisfactory evidence that the goods have been delivered to a destination outside of the UK. If satisfactory evidence is not obtained, then the supply cannot be zero-rated. Businesses that zero-rate supplies without obtaining the necessary proof that the goods have been exported may be subject to assessments for the amount of VAT that would be due if the goods had been sold in the UK, interest and potentially a penalty as well.

For in-depth commentary on the legislation and case law relating to proof of export, see De Voil Indirect Tax Service V4.302.