# Foreign currency VAT invoices as e-invoices: showing VAT in GBP
> You can invoice in euros or dollars, but HMRC wants total VAT in sterling. How to do that in a Peppol e-invoice with BT-6 and BT-111, and errors to avoid.
- Canonical URL: https://einvoices.uk/news/multi-currency-e-invoices-gbp
- Published: 20 October 2026 (2026-10-20)
- Last updated: 20 October 2026 (2026-10-20) (not updated since publication)
- Author: Floris Lindenaar, Editor, e-invoicing expert (https://einvoices.uk/authors/floris-lindenaar)
- Publisher: einvoices.uk (https://einvoices.uk)
- Type: Guide
- Topics: VAT, Technical, Peppol, Validation
- Language: en-GB (UK English); covers the United Kingdom
## Sources
- [Electronic invoicing (VAT Notice 700/63), 3.5 Currency on invoices – GOV.UK](https://www.gov.uk/guidance/electronic-invoicing-notice-70063)
- [VAT guide (VAT Notice 700), 7.6 and 16.4 – GOV.UK](https://www.gov.uk/guidance/vat-guide-notice-700)
- [Peppol BIS Billing 3.0 (May 2026 release, version 3.0.21), 11.6 VAT accounting currency](https://docs.peppol.eu/poacc/billing/3.0/bis/)
- [Rules for Peppol BIS 3.0 Billing](https://docs.peppol.eu/poacc/billing/3.0/rules/ubl-peppol/)
- [EN16931 model bound to UBL – Peppol BIS Billing 3.0 rules](https://docs.peppol.eu/poacc/billing/3.0/rules/ubl-tc434/)
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You can issue a UK VAT invoice in any currency, but HMRC requires the **total VAT in sterling** where UK VAT is due at a positive rate. In a Peppol e-invoice you do this with two fields: set the VAT accounting currency (BT-6, `cbc:TaxCurrencyCode`) to `GBP`, and give the total VAT in pounds (BT-111) in a second `cac:TaxTotal` that contains only an amount. Everything else, including the VAT breakdown, stays in the invoice currency.
## What HMRC requires
VAT Notice 700/63 (electronic invoicing), paragraph 3.5: "You may express the amounts in any currency. But you must express the total amount of VAT in sterling where there is a positive rate of VAT due in the UK."
VAT Notice 700, paragraph 16.4: if you issue VAT invoices in a foreign currency for supplies that take place in the UK, "you must convert the total amount of VAT payable into sterling".
Paragraph 7.6 (which "has force of law") sets out the conversion options:
- the UK market selling rate at the time of the supply (the default)
- HMRC's published period rates for customs purposes, used for all supplies or a class of supplies
- another commercial rate or method, but only if you apply in writing to HMRC and it is approved
"Whatever rate or method you adopt, the appropriate rate for any supply is that current at the time of the supply."
So the requirement is the **total** VAT in sterling. HMRC's notices do not require the net amounts or the per-rate breakdown in sterling.
## How EN 16931 models it
| Business term | Meaning | UBL |
|---|---|---|
| BT-5 Invoice currency code | Currency of all amounts | `cbc:DocumentCurrencyCode` |
| BT-6 VAT accounting currency code | Currency for VAT reporting | `cbc:TaxCurrencyCode` |
| BT-110 Invoice total VAT amount | VAT in the invoice currency | First `cac:TaxTotal/cbc:TaxAmount` |
| BT-111 Invoice total VAT amount in accounting currency | VAT in the VAT currency | Second `cac:TaxTotal/cbc:TaxAmount` |
Peppol's guidance quotes the EU VAT Directive's version of the same rule and explains: "If the invoice currency is different from the national currency, this is expressed in the invoice by stating the national currency in the element VAT accounting currency (BT-6), and the amount of VAT payable in national currency is stated in the element Invoice total VAT amount in accounting currency (BT-111)." The UK rule is the same shape, so the mechanism fits.
## Correct UBL: a euro invoice with VAT in sterling
A UK supplier invoices a UK customer €925.00 net, €173.00 VAT (20% on €865.00, plus €60.00 zero-rated). At an illustrative rate of £0.8650 per euro, the sterling VAT is £149.65.
```xml
EUR
GBP
173.00
865.00
173.00
S
20
VAT
60.00
0.00
Z
0
VAT
149.65
910.00
925.00
1098.00
15.00
1098.00
```
The full invoice passed the UBL 2.1 schema, the EN 16931 rules and the Peppol BIS Billing 3.0 rules with no errors. Every `currencyID` is `EUR` except the single GBP amount.
## The errors, and what causes them
We triggered each of these from the valid example above.
**Forgot the sterling total.** Setting `TaxCurrencyCode` but leaving out the second `TaxTotal`:
```text
[BR-53]-If the VAT accounting currency code (BT-6) is present, then the Invoice total VAT amount in accounting currency (BT-111) shall be provided.
PEPPOL-EN16931-R054 Only one tax total without tax subtotals MUST be provided when tax currency code is provided.
PEPPOL-EN16931-R055 Invoice total VAT amount and Invoice total VAT amount in accounting currency MUST have the same operational sign
```
**Put GBP on the wrong total.** Giving the main `TaxTotal/TaxAmount` (the one with subtotals) `currencyID="GBP"`:
```text
[BR-CO-15]-Invoice total amount with VAT (BT-112) = Invoice total amount without VAT (BT-109) + Invoice total VAT amount (BT-110).
PEPPOL-EN16931-R051 All currencyID attributes must have the same value as the invoice currency code (BT-5), except for the invoice total VAT amount in accounting currency (BT-111).
```
BR-CO-15 needs exactly one `TaxAmount` in the invoice currency. See [BR-CO-15 explained](https://einvoices.uk/news/peppol-validation-error-br-co-15).
**Set GBP as both currencies.** A sterling invoice with `TaxCurrencyCode` GBP fails **PEPPOL-EN16931-R005**: "VAT accounting currency code MUST be different from invoice currency code when provided." For GBP invoices, leave `cbc:TaxCurrencyCode` out.
**Signs differ.** On a negative invoice, both VAT totals must be negative (R055).
## The exchange rate
EN 16931 has no business term for the exchange rate or the rate date. If you want the buyer (or HMRC) to see how you got from €173.00 to £149.65, the usual approach is a short text in the invoice note (BT-22, `cbc:Note`), for example "VAT converted at HMRC period rate". Peppol allows only one document-level note (PEPPOL-EN16931-R002). Whether the UK specification will add an exchange rate field is **not yet confirmed**.
## When you don't need BT-6
- **Invoicing in GBP.** All amounts, including VAT, are already in sterling.
- **No positive-rate UK VAT.** HMRC's sterling rule applies "where there is a positive rate of VAT due in the UK". A zero-rated export invoiced in dollars has no sterling VAT to show. If your software adds BT-6 anyway, BR-53 then requires a BT-111 amount (0.00).
- **Reverse charge.** On AE invoices the VAT amount in the invoice is zero. See [reverse charge e-invoices](https://einvoices.uk/news/domestic-reverse-charge-construction-e-invoice).
## Paying in another currency
The payable amount (BT-115) is always in the invoice currency. Peppol has no field for a different settlement currency. If you want payment in sterling, invoice in sterling.
## What may change for the UK mandate
Everything above is Peppol BIS Billing 3.0 (May 2026 release) plus current HMRC guidance. The UK e-invoicing specification has not been published. It could, for example, require the sterling VAT per rate, or a structured exchange rate. **That is not confirmed.** Cross-border invoicing from a UK point of view is covered in [UK businesses selling to the EU](https://einvoices.uk/news/uk-businesses-selling-to-eu-e-invoicing).
## What to do now
- List which customers you invoice in a foreign currency, and check your software sets BT-6 and BT-111 for those invoices.
- Decide on and document your exchange rate method under VAT Notice 700 paragraph 7.6.
- Make sure the sterling VAT on the invoice matches what goes on your VAT return.
- See the full [UK Peppol invoice XML example](https://einvoices.uk/news/e-invoice-xml-example-uk).
## Frequently asked questions
### Can a UK VAT invoice be issued in euros?
Yes. HMRC allows amounts in any currency, but where UK VAT is due at a positive rate, the total VAT must also be shown in sterling.
### How do I show VAT in GBP on a Peppol invoice in another currency?
Set cbc:TaxCurrencyCode to GBP (BT-6) and add a second cac:TaxTotal with only a cbc:TaxAmount in GBP (BT-111). Everything else stays in the invoice currency.
### Which exchange rate should I use?
HMRC allows the UK market selling rate at the time of supply, HMRC's published period rates, or another rate agreed in writing with HMRC. Use the rate current at the time of supply.
### Can I put the exchange rate in the e-invoice?
EN 16931 has no dedicated exchange rate field. Some businesses add it as text in the invoice note. Whether the UK standard will add a field is not yet confirmed.
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How to cite: "Foreign currency VAT invoices as e-invoices: showing VAT in GBP", einvoices.uk, 20 October 2026, https://einvoices.uk/news/multi-currency-e-invoices-gbp
einvoices.uk is an independent publication and is not affiliated with HMRC or the UK Government. Nothing here is tax advice; check the sources and official GOV.UK guidance before acting.