UK VAT registration is the clear gap; California is at 84% of its threshold and New York is not triggered

Assumptions: "Washington" means Washington State. Figures are trailing 12 months (none stated). Registrations exist for California sales tax only. The seller is assumed to be a US business with no UK or EU establishment, shipping merch from a US warehouse (state unknown). SaaS and merch are tested separately. No SaaS/merch split was given, so no exposure figure is estimated. This is research support, not tax advice.

Obligation table

Jurisdiction	Tax type	Trigger and threshold	User's current figure	Status	Legal basis	Estimated exposure incl. lookback	Registration or filing steps	Deadline
California	Sales tax, physical goods (merch)	$500,000 combined sales of tangible personal property for delivery in California in the preceding or current calendar year	$420k total, 3,100 orders (84% of threshold, assuming all sales are merch)	Registered (already holds a permit; 84% means monitor)	CDTFA Wayfair guidance	Not applicable (registered)	Keep filing under existing permit	Per existing filing frequency (unchecked)
California	Sales tax, SaaS	Electronic digital products are not subject to California sales tax; SaaS treatment not separately verified	Not split	Not triggered (unverified taxability)	CDTFA Wayfair guidance	Not applicable	None identified	None identified
California	Rates	7.25% statewide rate (includes 1.25% local) plus district taxes of 0.10% to 2.00%, table effective 1 October 2026	n/a	Info	CDTFA rates	n/a	Local rates vary by address	n/a
New York	Sales tax, goods	More than $500,000 gross receipts from sales of tangible personal property into NY and more than 100 sales, over the preceding four sales tax quarters	$80k (16% of dollar test); 610 orders (passes the 100-sale test alone)	Not triggered	NY Tax Dept nexus page, updated 29 July 2026	None	If crossed, register within 30 days and collect 20 days after	Not applicable now
New York	Sales tax, SaaS	Prewritten software is taxable, including by remote access, as tangible personal property, so SaaS receipts likely count toward the nexus test (inference; adviser to confirm)	$80k total (not split)	Not triggered on dollars; unverified for SaaS counting	TB-ST-128, updated 31 March 2026	Rate unverified	Re-test if NY SaaS receipts grow	None now
Texas	Sales tax, goods	$500,000 in total Texas revenue in the preceding 12 calendar months	Not provided	Unchecked	Texas Comptroller remote sellers page	Not estimable	Apply online or Form AP-201 if crossed; permit by first day of the fourth month after exceeding	Not applicable until figure known
Texas	Sales tax, SaaS	Data processing services include software as a service; 20% of the charge is exempt	Not provided	Unchecked	Publication 96-259, January 2026	Rate unverified	As above	n/a
Washington	Retail sales tax	More than $100,000 combined gross receipts sourced to Washington, current or prior year	Not provided	Unchecked	WA DOR remote sellers page	Not estimable; rate unverified	Business license application flagged as remote seller, or Streamlined Sales Tax route; collect from the first day of the month at least 30 days after crossing	n/a until figure known
Washington	SaaS taxability	Not found (the DOR digital services page returned HTTP 403)	Not provided	Unchecked	n/a	Not estimable	n/a	n/a
United Kingdom	VAT registration, non-established seller	A business based outside the UK must register for VAT regardless of turnover if it supplies any goods or services to the UK	£65k, 900 orders; no VAT number	Triggered (inference: the £90,000 domestic threshold does not apply to overseas sellers)	GOV.UK Register for VAT	Not estimable: UK VAT rate unverified and the taxable base is not split. if you register late, you must pay VAT on any sales made since the date you should have registered, and a penalty may apply. Adviser needed	Register online via HMRC; then file VAT returns	Register now; late-registration penalty risk
United Kingdom	VAT on SaaS to UK consumers	Digital services such as software supplied to UK consumers are liable to UK VAT	Part of £65k (not split)	Triggered (same registration)	GOV.UK digital services guidance	As above	Charge UK VAT to consumers; keep records	As above
United Kingdom	VAT on merch shipped from US	Goods of £135 or less sent from outside the UK to Great Britain: VAT is charged at the point of sale and the seller must register. Above £135, import VAT applies	Part of £65k (average order about £72 if all merch, inference)	Triggered if any merch is sold to UK consumers at £135 or less	GOV.UK overseas goods guidance	As above	As above	As above
Germany	VAT via EU One Stop Shop (non-Union scheme), SaaS	The non-Union scheme lets non-EU businesses report VAT on services to EU consumers through one registration. No distinct Germany threshold verified	Not provided	Unchecked	BZSt OSS non-Union page	Not estimable; German rate unverified	Register in the BZStOnline portal; quarterly returns	Returns due 30 April, 31 July, 31 October and 31 January (nil returns required)
Germany	Merch shipped from US warehouse	Import and low-value consignment rules not retrieved	Not provided	Unchecked	Not found	Not estimable	n/a	n/a

Notes on rows that are not clean

California (84%): Registered, but any growth in sales delivered into California keeps you above the $500,000 test. If the US warehouse is in California, physical presence applies at any volume (adviser needed). SaaS taxability for California was not independently confirmed from a statute.
New York SaaS: Remote-access software is taxable, so the nexus counting rules for SaaS receipts need an adviser's view (unclear taxability).
Texas and Washington: No figures were supplied, so the economic thresholds are unchecked. Washington's $100,000 threshold is the most likely to be crossed.
United Kingdom: The non-established seller rule means the gap exists from the first UK sale, and you have 900 orders already. Retroactive VAT and penalties raise a voluntary-disclosure decision (adviser needed).
Germany/EU: No figures, so unchecked. Whether EU consumers are served at all is the first question.

Do next

United Kingdom: Confirm the date of the first UK sale and the SaaS/merch split, then talk to an adviser about registering and about disclosing back periods.
Washington: Pull Washington receipts and compare to $100,000.
Texas: Pull Texas receipts and compare to $500,000; check SaaS handling.
Germany/EU: Count EU consumer sales by country; if any exist, consider the OSS non-Union registration.
California and New York: Monitor monthly against $500,000 and $500,000 plus 100 sales.

Near misses and open items

California is at 84% of its threshold (computed: 420,000 / 500,000).
Not found: state sales tax rates for NY, TX and WA; UK and German VAT rates; Washington SaaS taxability; EU import rules for US-warehouse goods; filing frequencies.
No GBP conversion was needed, because the UK registration trigger is not a monetary threshold.

Coverage

Not reached: the Washington DOR digital services page (HTTP 403). Not searched in time: NY/TX/WA rate pages, UK and German VAT rate pages, EU import guidance.

Sources

Accessed 6 October 2026 unless a page date is shown.