NZ and NETP?

I emigrated from the UK four years ago and now live in New Zealand; however I still provide tax advice and complete UK tax returns for UK-based clients.

These are mainly private individuals but I do prepare a few business accounts and corporation tax returns for small companies. I trade through a UK limited company that is registered at the office of my accountant in Birmingham.

I have always ignored UK VAT because my total income has been below the VAT registration threshold. However having read Neil Warren’s recent article on the zero VAT registration threshold that applies to an NETP (a “non-established taxable person”) from 1 December 2012 I am worried that I might now have a problem.

That said it would appear from HMRC’s Notice 700/1 paragraph 9.2 that I am not an NETP because my company is incorporated...