The regimes you operate under.
Home-country income tax on trading profit, home-country sales tax/VAT/GST on domestic sales, the destination country’s VAT or sales tax regime (EU VAT 17-27% depending on member state, UK VAT 20%, Australia GST 10%, Canada GST/HST 5-15%, US state sales tax 0-10%), and Shopify marketplace facilitator rules where applicable. None of these subsume the others. You usually owe at least two simultaneously.
The simplification many merchants attempt: treat exports as zero-rated and forget about destination VAT. That works only if the customer self-imports and pays VAT on entry. For low-value parcel ecommerce, the customer usually does not, and the burden either lands on you (registered destination VAT) or on Shopify (marketplace facilitator).
EU VAT and the OSS scheme.
The EU runs the One-Stop Shop (OSS) for distance B2C sales. Above €10,000 in cross-border B2C sales to EU customers in a calendar year, you must register for OSS (or in each destination country individually) and collect VAT at the customer’s country rate. Below €10,000, you can charge home-country VAT.
For low-value imported goods (consignments under €150), the Import One-Stop Shop (IOSS) lets a non-EU seller collect VAT at point of sale and remit through a single EU country. Without IOSS, the parcel is held at customs and the customer is hit with a surprise VAT bill plus a handling fee, which destroys conversion. Most serious cross-border sellers register for IOSS.
UK VAT post-Brexit.
Since Brexit, the UK treats EU sellers like any other foreign seller. Orders under £135 require the seller to register for UK VAT and collect at the point of sale; Shopify, when acting as marketplace facilitator, handles this for some configurations. Orders over £135 follow standard import rules: VAT and duty paid at the border by the importer.
MTD (Making Tax Digital) for VAT requires digital VAT returns submitted through approved software. Spreadsheet-only VAT returns are no longer accepted in the UK. Your accounting stack needs an MTD-compliant VAT filing path. Nonari produces MTD-ready VAT return data per UK-registered branch.
US sales tax and the Wayfair regime.
After South Dakota v. Wayfair (2018), states can require remote sellers above economic thresholds to collect sales tax. The most common threshold is $100,000 in sales OR 200 transactions per state per year. Some states (Kansas) have no threshold; some (California) only the dollar threshold. A Shopify merchant doing volume into 10 states can owe in 10.
Marketplace facilitator laws shift the obligation when you sell via Amazon, eBay, Etsy, or Walmart. Direct Shopify sales remain your obligation unless you use Shopify Tax (which collects in registered states automatically). Form 1099-K reporting from Shopify is now triggered at $5,000 in 2026, down from $20,000, so even small sellers receive 1099-Ks.
- Economic nexus: register and collect once you cross the state threshold
- Marketplace facilitator: Amazon/eBay/Etsy collect on your behalf
- Shopify Tax: opt-in service that handles registered-state collection
- 1099-K: now $5,000 threshold for 2026 reporting
Customs duty and the de minimis quirks.
Goods crossing borders are subject to customs duty (varies by HS code) and destination VAT or sales tax. The customer pays unless you ship DDP (delivered duty paid). DDP is increasingly the norm because customer-paid duty leads to refused parcels and chargebacks. If you ship DDP, the duty plus destination VAT is a cost you bear.
Journal for a DDP order: gross sale at storefront price, COGS at WAC, plus a Customs and duty expense for the duty paid on entry. If destination VAT was prepaid by you on entry, it is also a cost (or a recoverable receivable if you are VAT-registered in the destination). Many merchants miss the duty line entirely and book the customs invoice as freight, distorting both expense categories.
Australia and Canada.
Australia applies 10% GST on low-value imports (under AUD 1,000) where the seller has more than AUD 75,000 in sales into Australia per year. Above that threshold, you must register, collect, and remit. The ATO publishes clear guidance and Shopify Tax can handle the collection automatically.
Canada applies federal GST (5%) plus provincial sales tax (PST/HST) ranging from 0% to 10%, depending on the province. Non-resident sellers above CAD 30,000 in sales into Canada must register and collect. Some provinces have their own thresholds. Cross-border to Canada is one of the more fragmented tax landscapes; expect to manage 5+ separate registrations if you sell at scale.
Per-branch tax tracking.
In Nonari, each Shopify storefront is its own branch with its own tax configuration. A US storefront tracks state sales tax per state. A UK storefront tracks UK VAT (or marks it as marketplace-facilitator-collected). An EU storefront tracks OSS-collected VAT. Tax collected sits in jurisdiction-specific liability accounts so you know exactly what you owe to whom.
At month end, each tax liability has its own filing trigger. EU OSS files quarterly. UK VAT files quarterly under MTD. US state sales tax files monthly, quarterly, or annually depending on the state and volume. Per-branch tracking means you never mix them, never under-remit, and never need a forensic accountant after the fact.
Where Nonari fits.
Nonari is built per-branch, per-currency, per-tax-jurisdiction from the foundation. The Shopify connection is per online branch, AES-256-GCM encrypted credentials, with marketplace facilitator awareness on import so you can mark whether Shopify or you are the deemed supplier. Tax liabilities accumulate by jurisdiction. FX flows through a dedicated gain/loss account.
For a US merchant launching a UK storefront, the upgrade is adding a second branch with the destination tax configuration. Books consolidate in USD, the cross-border revenue stream is visible separately, customs and duty expenses sit in their own line, and your UK VAT return is MTD-ready. None of this requires a separate cross-border tax accountant.