Urgent action is required if you incur EU VAT in the member states and recover the VAT through the online EU reclaim portal.
HMRC have advised that in the event of a no deal Brexit, the 2018 EU VAT claim will need to be submitted by 29 March 2019 when the UK leaves the EU, extract below:
The normal deadline of 30 September 2019 will not apply. It is not yet clear how an extension of Brexit would affect the EU reclaim deadline.
What happens after the UK leaves the EU?
After the UK leaves the EU, the EU VAT may still be claimed by using the process for non-EU businesses however this scheme has different procedures, claim periods and filing dates specific to each member state. As a result, the period 1 January 2018 to 30 June 2018 may already be considered as out of time using the non-EU mechanism, so claims for this period should be submitted before 29 March, using the EU system. Under the non-EU claim process it is also necessary to provide an original certificate from HMRC as proof of your business activity to support the claim. Each member states’ interpretation may differ and it would be necessary to clarify the position if you are intending to reclaim EU VAT after the UK leaves the EU following a no deal.
As there is much uncertainty about the UK position in respect of the deal agreed and the Brexit date, we advise preparing and filing the 2018 calendar year EU reclaim by the potential earlier deadline of 29 March 2019.