Rules and ethics
How EU and UK beauty brand deals differ for UK creators after Brexit: fees, samples, tax and contracts
A deal-by-deal comparison of an EU beauty brand offer and a UK one for a UK creator after Brexit: net fees, sample customs, VAT, withholding tax, contract terms and advertising rules.
A UK beauty creator weighing an offer from an EU brand against one from a UK brand should compare six things in order:
- The work, deliverables and responsibilities, not just the headline fees.
- What each offer may leave after currency conversion, costs and withholding.
- Any sample shipment, paperwork and customs charges, planned before dispatch.
- VAT, withholding tax and treaty relief, treated as separate questions.
- Payment, rights, approvals and delivery requirements, agreed in writing.
- The complete EU and UK offers side by side before choosing.
Scope the assignment
Start by comparing the work and responsibilities attached to each offer. An EU beauty partnership is not automatically better value than a UK deal: check deliverables, approvals, sample handling, payment currency, content rights and dispute terms before judging the expected amount left after costs.
Write down what each party will do, including who handles shipping, payment and approvals. Put material promises in the contract rather than leaving them in informal messages. The contract terms and risk scenarios help identify responsibilities and uncertainties to settle before accepting.
Value the fee in pounds
Compare likely net receipts rather than the amount printed on the offer. A euro fee can convert to a different sterling amount as exchange rates move, while withholding and transfer charges may reduce the payment. Agree the currency and conversion approach before signing, including who carries the exchange-rate risk.
Campaign expenses belong in the comparison too. Shipping, currency conversion fees and accountancy costs can change what remains, making them hidden costs to allow for when assessing the fee.
| Deal | Gross fee | Exchange rate | Gross in GBP | Net if no withholding | Net if 15% withholding |
|---|---|---|---|---|---|
| Domestic | £5,000 | n/a | £5,000 | £5,000 | n/a |
| Domestic | £10,000 | n/a | £10,000 | £10,000 | n/a |
| Domestic | £20,000 | n/a | £20,000 | £20,000 | n/a |
| EU | €5,000 | 1.10 | £4,545 | £4,545 | £3,864 |
| EU | €5,000 | 1.15 | £4,348 | £4,348 | £3,696 |
| EU | €5,000 | 1.20 | £4,167 | £4,167 | £3,542 |
| EU | €10,000 | 1.10 | £9,091 | £9,091 | £7,727 |
| EU | €10,000 | 1.15 | £8,696 | £8,696 | £7,391 |
| EU | €10,000 | 1.20 | £8,333 | £8,333 | £7,083 |
| EU | €20,000 | 1.10 | £18,182 | £18,182 | £15,455 |
| EU | €20,000 | 1.15 | £17,391 | £17,391 | £14,783 |
| EU | €20,000 | 1.20 | £16,667 | £16,667 | £14,167 |
These examples are rounded to the nearest pound and use illustrative exchange rates, not forecasts. They exclude shipping, currency conversion fees and accountancy costs, so they are not full profit estimates. Any withholding shown may be recoverable under a treaty, although a reclaim can take time.
Plan sample movements
When samples must cross the UK-EU border, plan customs paperwork and clearance before dispatch. Confirm who will arrange export and import steps, and who pays any resulting customs charges, so shipping does not become an unpriced campaign obligation.
A GB EORI number, commercial invoice, packing list and customs declaration may be needed for clearance. The EU brand may need its own EU EORI when importing the products. Tariff treatment depends on the rules of origin: zero tariffs may apply when goods qualify under the UK-EU Trade and Cooperation Agreement and the required origin statement supports the claim.
| Shipping method | Typical cost | What it covers |
|---|---|---|
| Courier, 1 to 2 kg parcel | £30 to £60 | Door-to-door delivery, with customs clearance included or charged at £15 to £25 per entry |
| Freight forwarder, 50 to 100 kg pallet | £150 to £400 | Export documents, customs clearance and delivery to the brand |
| Customs clearance fee | £15 to £25 per entry | Broker fee when the courier or forwarder does not include it |
| Import VAT | 20% of the customs value plus any duty and shipping to the UK border, if applicable | Paid by the importer unless the shipment is zero-rated or exempt |
| Duty | Often 0% for perfume and make-up headings; check the commodity code on the UK Trade Tariff | Depends on the product and on whether the origin rules are met |
Treat these as illustrative planning ranges, not quotes or published tariffs: the final charge depends on parcel weight, service level and broker. Beauty products can have complex supply chains, so check the goods' origin instead of assuming it from the brand or dispatch location. Keep the customs declaration and evidence supporting origin with the campaign records.
Free products sent to a creator to post about are usually promotional, so HMRC's commercial samples relief, which is meant for samples sent to win orders, generally does not cover them. Expect to declare a realistic value even when the invoice says free of charge, and expect import VAT of 20% on that value. Marking a parcel "no commercial value" does not mean a value of zero.
Separate tax exposures
For a UK creator supplying a business service to an EU client, the general place-of-supply rule locates the service where the customer belongs, so UK VAT may not be charged; VAT registration and return reporting still need separate checks, as a tax adviser can confirm.
A UK deal is simpler. A UK brand paying a UK-resident creator's service fee does not deduct tax from it, so the creator reports the income on a Self Assessment return and charges 20% UK VAT if registered. The comparison below therefore treats withholding as an EU-side question, not a UK one.
Withholding tax is separate from VAT. Some EU countries may deduct tax from payments to non-residents, while service-fee treatment depends on the relevant treaty and whether the creator has a permanent establishment there. The rates and procedures below are points to check, not a substitute for advice on a particular contract.
| Country | Typical withholding on service fees | Other rates to check | Treaty reclaim steps | Typical timeline |
|---|---|---|---|---|
| France | Often none under the treaty if you have no French permanent establishment; check French rules on payments for services used in France | Royalties may attract French withholding domestically, usually reduced to 0% under the UK-France treaty | Obtain HMRC form DT Individual to certify UK residence; file French tax office form 5000 for the relevant income | Several months |
| Germany | Often none, but German withholding on payments to non-resident performers (Section 50a of the Income Tax Act) can apply to work done in Germany | Royalties 15% plus solidarity surcharge, often reduced to 0% under the UK-Germany treaty | Obtain HMRC form DT Individual; file a refund application with the Bundeszentralamt für Steuern (BZSt) | Several months |
| Netherlands | Usually none on service fees | No general Dutch withholding on royalties; check the treaty for other income | Obtain HMRC form DT Individual; file a refund form with the Belastingdienst if tax was withheld | Several months |
The table separates service fees from royalties, which can receive different treatment. A reclaim may require residence certification and a filing with the relevant national authority; allow for delays when planning cash flow. Confirm the applicable tax treaty before relying on a rate or estimating relief on income from abroad.
Fix delivery terms
Set payment, rights and campaign duties out clearly in the agreement. An EU brand may propose its home jurisdiction, so consider whether English law or a neutral option is preferable and assess the practical consequences of unfamiliar dispute terms before accepting.
State the amount, currency, due date and payment method, including what happens if payment is late. If the brand pays in euros, decide which party carries exchange-rate risk and reflect that allocation when setting the fee. A fixed fee, retainer or affiliate arrangement may affect how income is received, so compare the pricing models with the campaign's work and costs.
For created content, specify copyright ownership and the uses the brand is licensed to make. Creators usually retain copyright unless the contract transfers it, while a brand may request wider ownership. Define duration, territory and permitted use; if your name is licensed for products, set out scope, duration and royalties.
Paid partnerships need clear disclosure, and campaign claims must not mislead consumers. For UK audiences, the Advertising Standards Authority enforces the CAP Code and the Competition and Markets Authority enforces consumer law. For EU audiences, check each market's rules and self-regulator, such as the ARPP in France, the Deutscher Werberat in Germany and the Reclame Code Commissie in the Netherlands. Review the service standards and UK consumer law changes for beauty influencers alongside the agreement, especially where audience data is collected.
Compare the complete offers
An EU offer can involve customs, currency conversion and possible treaty claims; a UK offer may be simpler to administer. Neither label establishes value by itself. Compare the actual obligations, expected cash received and contract terms for the specific campaign before deciding.
| Aspect | EU deal | UK deal |
|---|---|---|
| Customs paperwork | Needed for shipped samples, including a commercial invoice and EORI | Not needed for domestic movement |
| Governing law | May be an EU country's law | Often English law |
| Payment currency | May be euros, creating exchange-rate risk | Often pounds sterling |
| Withholding tax | May apply; treaty relief may be available | No withholding tax in the comparison provided |
| IP ownership | Confirm ownership and licence terms | Creator usually retains copyright unless the contract provides otherwise |
| Dispute resolution | May involve EU courts | May involve UK courts |
| Additional administration | Can include customs and tax records | Usually less cross-border administration |
The comparison above sets out typical terms by deal type, since the actual terms differ by campaign. A brand's location does not settle them, so compare each written offer you receive against the same rows. The micro and macro creator choice is separate from cross-border costs and obligations.
An EU offer may carry a higher gross fee but leave less after shipping, conversion and possible withholding. A UK offer may be more predictable yet still needs clear payment, rights and delivery terms. Decide using the full costs, responsibilities and expected cash received, then negotiate any condition that could change the comparison.
