EU VAT for online sellers: OSS, IOSS and the EUR 10,000 threshold

Where the VAT is due in the country of delivery, it is charged at that country’s rate (Art. 33Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 33Click opens the article on EUR-Lex.), whether you are based in the EU or not. What changes from seller to seller is how you declare it, and in some cases whether you declare it at all.

When EU VAT reaches your sale

A sale of goods to a consumer in another EU country, shipped by you or on your behalf, is a distance sale. The law has two kinds: goods shipped from one EU country to another, and goods shipped into the EU from outside it (Art. 14(4)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 14, paragraph 4Click opens the article on EUR-Lex.). Goods shipped between EU countries are taxed where the delivery ends (Art. 33(a)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 33, point (a)Click opens the article on EUR-Lex.). Imported goods are taxed there too when they enter the EU in another country than the one they are delivered to, or when you declare them through IOSS (Art. 33(b)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 33, point (b)Click opens the article on EUR-Lex., Art. 33(c)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 33, point (c)Click opens the article on EUR-Lex.). A parcel imported straight into its destination country without IOSS pays import VAT at the border instead, paid by the person that country names (Art. 201Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 201Click opens the article on EUR-Lex.). Every parcel above EUR 150 pays import VAT at the border, as IOSS does not take it (Art. 369lDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369lClick opens the article on EUR-Lex.). If your customer is the importer, you charge no EU VAT on the sale; if you import the goods yourself, your sale is made in the country of import and carries its VAT (Art. 32Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 32Click opens the article on EUR-Lex.). From 1 July 2028, on a parcel up to EUR 150 sold without IOSS, the law makes you liable for the import VAT, so your sale is made there (Council Directive (EU) 2025/1539, Art. 1(1)). Being based outside the EU does not take you out of any of this: the rules look at where the goods go, not where the seller sits.

“On your behalf” is wide. Goods count as shipped by the seller where the seller subcontracts the delivery, carries any responsibility for it, invoices the customer for shipping and pays a carrier, or only promotes a carrier’s service or hands the carrier the delivery details. They do not count where the customer collects the goods or arranges the delivery with someone the seller never helps (Art. 5aImplementing Regulation (EU) No 282/2011, VAT implementing measures (consolidated text of 14 April 2025)Article 5aClick opens the article on EUR-Lex.). A drop-shipped parcel is a distance sale by whoever sold it to the consumer.

Each EU country sets its own standard VAT rate, the same for goods and services, and none may set it below 15% (Art. 96Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 96Click opens the article on EUR-Lex., Art. 97Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 97Click opens the article on EUR-Lex.). Reduced rates, and which products take them, differ by country too. The Commission keeps the links to each country’s tax authority on its country-specific VAT page.

TEDB’s latest entries are dated 1 July 2026 for 24 countries, 1 January 2026 for Cyprus and Portugal, and 1 January 2025 for Greece. TEDB also lists 7% for Spain under “VAT - Canary Islands”; the VAT Directive does not apply to the Canary Islands (Art. 6(1)(b)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 6, paragraph 1, point (b)Click opens the article on EUR-Lex.), so that is not Spain’s standard rate. Some regions apply lower rates in place of the mainland one under Art. 104Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 104Click opens the article on EUR-Lex.: TEDB lists 16% for the Azores and 22% for Madeira (1 January 2026), and 17% for the Greek islands of Leros, Lesvos, Kos, Samos and Chios (1 January 2025). The rate that counts is the one in force when the VAT becomes chargeable.

How the EUR 10,000 threshold works

The threshold keeps a small cross-border trade on home VAT, and it has three conditions, all of which must hold. Your business is established in only one EU country. The goods ship to consumers in other EU countries. And the total of those sales, without VAT, is at or under EUR 10,000 in the current calendar year and was in the year before (Art. 59c(1)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 59c, paragraph 1Click opens the article on EUR-Lex.). Then those sales are taxed as if they were made at home, and OSS has nothing to declare, unless you choose destination VAT (Art. 59c(3)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 59c, paragraph 3Click opens the article on EUR-Lex.).

Cross EUR 10,000 during a year and the destination country’s VAT applies from that moment, not from the next year (Art. 59c(2)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 59c, paragraph 2Click opens the article on EUR-Lex.). The same total stays over the line for the whole of the following year, because the previous year counts too.

The EUR 10,000 is one figure for goods and for telecommunications, broadcasting and electronic services together, not a figure per country or per kind of sale. It covers goods shipped from the country where you are established; the Commission states that a business established outside the EU with one or more fixed establishments in it cannot use the threshold at all (Commission, The One Stop Shop). Below the threshold you may still choose destination VAT, and that choice binds you for two calendar years (Art. 59c(3)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 59c, paragraph 3Click opens the article on EUR-Lex.). From 1 January 2027, a Union scheme registration counts as that choice (ViDA Art. 2Directive (EU) 2025/516, VAT in the Digital Age (ViDA)Article 2Click opens the article on EUR-Lex., point (4)).

How OSS gives you one return instead of a registration in every country

Without the one-stop shop, VAT due in another EU country means a VAT registration in that country; each EU country runs its own registration and its own return (Art. 214Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 214Click opens the article on EUR-Lex., Art. 250Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 250Click opens the article on EUR-Lex.). OSS replaces those for your distance sales; VAT OSS sets out the schemes, the registration and the returns. You register in one EU country, and one quarterly return lists, for each destination country, the sales, the rates and the VAT due. You pay the total to that one country by the end of the month after the quarter, and it passes the money on (Art. 369fDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369fClick opens the article on EUR-Lex., Art. 369gDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369gClick opens the article on EUR-Lex., Art. 369iDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369iClick opens the article on EUR-Lex.). A quarter with no sales still gets a return.

The Union scheme, which is the OSS for goods, is open to any business making distance sales of goods inside the EU, whether it is based in the EU or not (Art. 369bDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369bClick opens the article on EUR-Lex.). It is optional, but it is all or nothing: once you use it, every sale it covers, to every EU country, goes through it (Art. 369bDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369bClick opens the article on EUR-Lex.).

Where you register depends on where you are based. A business established in the EU registers in its home country, and uses the VAT number it already has there. A business established outside the EU with no fixed establishment in it registers in the EU country its goods ship from; if they ship from more than one, it picks one and is bound to it for that year and the two following (Art. 369a(2)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369a, paragraph 2Click opens the article on EUR-Lex., Art. 369dDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369dClick opens the article on EUR-Lex.).

The scheme starts on the first day of the next calendar quarter after you tell your country of registration. If your first sale comes earlier, it starts from that sale, provided you tell that country by the 10th day of the month after it (Art. 57d(1)Implementing Regulation (EU) No 282/2011, VAT implementing measures (consolidated text of 14 April 2025)Article 57d, paragraph 1Click opens the article on EUR-Lex.). Leaving works the other way: tell the country at least 15 days before the end of a quarter, and you are out from the first day of the next one (Art. 57g(1)Implementing Regulation (EU) No 282/2011, VAT implementing measures (consolidated text of 14 April 2025)Article 57g, paragraph 1Click opens the article on EUR-Lex.).

A mistake in a filed return is corrected in a later return, within three years of the date the first one was due (Art. 369g(4)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369g, paragraph 4Click opens the article on EUR-Lex.). VAT you paid in a destination country is not deducted in the OSS return; it is refunded through the separate refund procedure, or deducted in that country’s own return if you are registered there anyway (Art. 369jDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369jClick opens the article on EUR-Lex.). The OSS return does not replace the VAT return you already file at home (Commission, The One Stop Shop).

How IOSS works for parcels up to EUR 150 from outside the EU

For goods shipped from outside the EU to an EU consumer in a consignment with an intrinsic value up to EUR 150, the import one-stop shop moves the VAT from the border to the checkout (Art. 369lDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369lClick opens the article on EUR-Lex.). You charge the destination country’s VAT when the customer pays, and the sale is taxed at the moment the payment is accepted (Art. 369nDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369nClick opens the article on EUR-Lex.). Your IOSS number goes to customs with the import declaration, and the parcel enters without import VAT (Art. 143(1)(ca)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 143, paragraph 1, point (ca)Click opens the article on EUR-Lex.). Once a month, you file one IOSS return for all EU countries and pay it by the end of the following month (Art. 369sDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369sClick opens the article on EUR-Lex., Art. 369vDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369vClick opens the article on EUR-Lex.).

A business based outside the EU needs an intermediary to use IOSS: a person established in the EU who becomes liable for the VAT and files and pays on your behalf. You can have only one at a time (Art. 369lDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369lClick opens the article on EUR-Lex., Art. 369m(1)(b)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369m, paragraph 1, point (b)Click opens the article on EUR-Lex., Art. 369m(2)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369m, paragraph 2Click opens the article on EUR-Lex.). Once you use IOSS, every such sale goes through it (Art. 369m(1)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369m, paragraph 1Click opens the article on EUR-Lex.).

Import VAT is not the only charge on these parcels: they now pay customs duty. The EUR 150 customs duty relief was deleted with effect from 1 July 2026 (Council Regulation (EU) 2026/382, Art. 1). From 1 July 2026 until 1 July 2028 a duty of EUR 3 per item applies instead, to goods imported under IOSS and to goods in a postal consignment (Council Regulation (EU) 2026/382, Art. 2). “Postal consignment” is a defined term, not a parcel sent by post: “goods in a consignment of an intrinsic value not exceeding EUR 150, sold in distance sales of imported goods”, excluding goods imported under IOSS and “goods which benefit from preferential measures” (Art. 1(24) of Delegated Regulation (EU) 2015/2446). So the EUR 3 reaches a parcel up to EUR 150 that you sell to an EU consumer, with or without IOSS, whatever the carrier, unless it goes without IOSS and its goods claim a tariff preference. The ordinary customs duty for the goods applies only to a consignment of EUR 150 or less that is not a distance sale, such as a sale to a VAT-registered business, and to goods under preferential measures that are not imported under IOSS. An item is not a piece: it is “one or more goods in a consignment sharing the same tariff classification, description and, if provided […], origin” (Art. 1(61) of Delegated Regulation (EU) 2015/2446). Whoever declares the parcel at customs needs an EORI number.

Intrinsic value is the price of the goods themselves, without transport and insurance unless those are included in the price and not shown separately on the invoice, and without other taxes and charges (Art. 1(48) of Delegated Regulation (EU) 2015/2446). Goods subject to excise duty, such as alcohol and tobacco, are outside IOSS whatever their value (Art. 369lDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369lClick opens the article on EUR-Lex.). IOSS covers goods shipped from outside the EU only; goods already in an EU warehouse are not imported distance sales (Commission, The One Stop Shop).

The intermediary registers first in its own EU country and receives an intermediary number; it then registers each seller it represents and receives a separate IOSS number for each (Art. 369qDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369qClick opens the article on EUR-Lex.). EU countries may add conditions for intermediaries, such as a guarantee (Commission, Register to OSS). A seller based in a country with which the EU has a VAT recovery assistance agreement, shipping from that country, may register without an intermediary (Art. 369m(1)(c)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369m, paragraph 1, point (c)Click opens the article on EUR-Lex.); the Commission’s example is Norway, and the exemption ends as soon as goods also ship from elsewhere. IOSS applies from the day the IOSS number is allocated (Art. 57d(2)Implementing Regulation (EU) No 282/2011, VAT implementing measures (consolidated text of 14 April 2025)Article 57d, paragraph 2Click opens the article on EUR-Lex.).

Without IOSS, the VAT is still due, only at the border. Until 30 June 2028, for a parcel up to EUR 150, the person presenting it to customs, in practice the post or the courier, may collect the import VAT from your customer and pay it over monthly (Art. 369yDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369yClick opens the article on EUR-Lex., Art. 369zDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369zClick opens the article on EUR-Lex., Art. 369zbDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369zbClick opens the article on EUR-Lex.), and the country of import may apply its standard rate to every such parcel (Art. 369zaDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369zaClick opens the article on EUR-Lex.). Your customer pays before delivery. From 1 July 2028 those special arrangements are deleted: on a parcel up to EUR 150 sold without IOSS, you, or the marketplace treated as the seller, owe the import VAT, and a seller established in a country that has a VAT assistance agreement with neither the EU nor the country of import appoints a tax representative there (Council Directive (EU) 2025/1539, Art. 1(1), Art. 1(6), Art. 2(1)). Above EUR 150 the parcel goes through a full import, and import VAT is paid by whoever the country of import names (Art. 201Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 201Click opens the article on EUR-Lex.). Without IOSS, a parcel of EUR 150 or less that you sold to an EU consumer is a postal consignment in law, whatever the carrier, and still pays the EUR 3 per item (Council Regulation (EU) 2026/382, Art. 2; Art. 1(24)Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeArticle 1, paragraph 24Click opens the article on EUR-Lex. of Delegated Regulation (EU) 2015/2446Delegated Regulation (EU) 2015/2446, supplementing the Union Customs CodeThe whole regulationClick opens the law on the EU Publications Office.). Goods under preferential measures pay the ordinary customs duty instead.

The articles: Art. 369bDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369bClick opens the article on EUR-Lex., Art. 369dDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369dClick opens the article on EUR-Lex., Art. 369fDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369fClick opens the article on EUR-Lex. for OSS; Art. 369lDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369lClick opens the article on EUR-Lex., Art. 369mDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369mClick opens the article on EUR-Lex., Art. 369qDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369qClick opens the article on EUR-Lex., Art. 369sDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369sClick opens the article on EUR-Lex. for IOSS. The IOSS number is not an EORI number: the IOSS number is a VAT number used “only for the purposes of this special scheme” (Art. 369q(4)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369q, paragraph 4Click opens the article on EUR-Lex.), and the EORI number is your customs identifier (Art. 9Regulation (EU) No 952/2013, Union Customs CodeArticle 9Click opens the article on EUR-Lex.): EORI number.

The Commission: “Member States are free to choose how they collect this information from the taxable person, but it must be provided electronically. In practice, Member States will provide a web portal for the submission of this information.”

When the marketplace pays the VAT

A marketplace, platform or portal that facilitates a sale is treated, for VAT, as if it bought the goods from you and sold them to the customer itself. That happens in two cases only (Art. 14aDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 14aClick opens the article on EUR-Lex.):

• goods imported from outside the EU in a consignment with an intrinsic value up to EUR 150, sold to an EU consumer, whoever the seller is (Art. 14a(1)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 14a, paragraph 1Click opens the article on EUR-Lex.);
• goods sold inside the EU to an EU consumer by a seller not established in the EU, at any value (Art. 14a(2)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 14a, paragraph 2Click opens the article on EUR-Lex.).

In both cases the marketplace charges the VAT to the customer and declares it. For an EU-based seller, the marketplace pays only on the imported parcels up to EUR 150; every other sale through it stays yours to declare, through OSS or a local registration.

Separately, a marketplace reports the sales of its sellers resident in the EU to tax authorities once a year under DAC7. That is reporting; it adds no tax.

“Facilitates” means the platform lets a customer and a seller come into contact through it, and a sale results through it. A platform does not facilitate where it sets none of the terms of the sale, takes no part in authorising the customer’s payment, and takes no part in the ordering or delivery. One that only processes payments, only lists or advertises goods, or only sends customers to another site to buy is outside the rule (Art. 5bImplementing Regulation (EU) No 282/2011, VAT implementing measures (consolidated text of 14 April 2025)Article 5bClick opens the article on EUR-Lex.). Selling from your own website, with a payment provider taking the money, puts no deemed supplier between you and the customer; the VAT stays yours.

In the second case your own sale to the marketplace is exempt, and you keep the right to deduct the VAT you paid on it (Art. 136aDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 136aClick opens the article on EUR-Lex., Art. 169Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 169Click opens the article on EUR-Lex.). The transport is ascribed to the marketplace’s sale (Art. 36bDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 36bClick opens the article on EUR-Lex.), and the VAT on both sales becomes chargeable when the customer’s payment is accepted (Art. 66aDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 66aClick opens the article on EUR-Lex.). The marketplace keeps records of these sales for 10 years, detailed enough for each EU country to check the VAT (Art. 242aDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 242aClick opens the article on EUR-Lex.).

The marketplace relies on what you tell it. Unless it knows otherwise, it treats you as a business and your buyer as a consumer (Art. 5dImplementing Regulation (EU) No 282/2011, VAT implementing measures (consolidated text of 14 April 2025)Article 5dClick opens the article on EUR-Lex.). It is not liable for more VAT than it declared where it depended on your information, the information was wrong, and it could not reasonably have known (Art. 5cImplementing Regulation (EU) No 282/2011, VAT implementing measures (consolidated text of 14 April 2025)Article 5cClick opens the article on EUR-Lex.). Wrong data from you leaves the gap with you.

What the invoice shows, in short (Art. 226Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 226Click opens the article on EUR-Lex.):

• the date of issue, and a sequential number that identifies the invoice uniquely;
• your VAT number; the customer’s too where the customer pays the VAT or it is an exempt supply to a business in another EU country;
• both parties’ full names and addresses;
• what was sold and how much, and the date of supply where it differs;
• the taxable amount per rate, the unit price without VAT, and any discount;
• the VAT rate and the VAT amount;
• for an exempt supply, the exemption reference; where the customer pays the VAT, the words “Reverse charge”.

Art. 220(1)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 220, paragraph 1Click opens the article on EUR-Lex., point (2), names “supplies of goods as referred to in point (a) of Article 33Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)The whole regulationClick opens the law on the EU Publications Office. except where a taxable person is making use of the special scheme in Section 3 of Chapter 6 of Title XII”, which is OSS.

What changes when your stock sits in an EU warehouse

A sale from a warehouse in one EU country to a consumer in the same country is a domestic sale there (Art. 32Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 32Click opens the article on EUR-Lex.), not a distance sale, and OSS does not take it. You need a VAT registration in that country for those sales (Art. 214(1)(a)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 214, paragraph 1, point (a)Click opens the article on EUR-Lex.). Even through a deemed-supplier marketplace you usually need one: your deemed sale to the marketplace is exempt with the right to deduct (Art. 136aDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 136aClick opens the article on EUR-Lex., Art. 169(b)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 169, point (b)Click opens the article on EUR-Lex.). Bringing the stock in, or moving it between countries, still needs a registration (Art. 17Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 17Click opens the article on EUR-Lex., Art. 201Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 201Click opens the article on EUR-Lex.).

Moving your own stock from one EU country to another is itself taxed. The move counts as a supply in the country the goods leave (Art. 17(1)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 17, paragraph 1Click opens the article on EUR-Lex.), and as an acquisition in the country they arrive in (Art. 21Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 21Click opens the article on EUR-Lex.), which calls for a VAT registration there (Art. 214(1)(b)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 214, paragraph 1, point (b)Click opens the article on EUR-Lex.). How each country runs that registration, and what it asks for, each EU country sets. Germany’s is on Germany VAT registration. France’s is on France VAT registration. Italy’s is on Italy VAT tax representative. Spain’s is on Spain VAT tax representative. The United Kingdom, outside the EU, is on UK VAT registration.

With stock in several EU countries, that is one VAT registration in each, and every move of your own stock between them is reported. The move is exempt in the country it leaves (Art. 138(2)(c)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 138, paragraph 2, point (c)Click opens the article on EUR-Lex.) and goes in that country’s EC Sales List (Art. 262(1)(a)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 262, paragraph 1, point (a)Click opens the article on EUR-Lex.); its arrival is taxed where the goods arrive (Art. 21Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 21Click opens the article on EUR-Lex.).

What changes on 1 July 2028. Directive (EU) 2025/516Directive (EU) 2025/516, VAT in the Digital Age (ViDA)The whole regulationClick opens the law on the EU Publications Office., VAT in the Digital Age, opens the Union scheme to a seller not established in the country where goods are sold without cross-border transport, or where the transport begins and ends in that same country, so a warehouse sale to a consumer in the same country can be declared through OSS (Art. 3Directive (EU) 2025/516, VAT in the Digital Age (ViDA)Article 3Click opens the article on EUR-Lex., new Article 369b, point (e)). EU countries apply it from 1 July 2028 (Art. 6(3)Directive (EU) 2025/516, VAT in the Digital Age (ViDA)Article 6, paragraph 3Click opens the article on EUR-Lex.). Until then, those sales need a local registration.

When an EU country requires a tax representative

An EU country may require a business not established there to appoint a tax representative, where its home country has no mutual assistance instrument of similar scope; whether it does is that country’s choice (Art. 204(1)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 204, paragraph 1Click opens the article on EUR-Lex., second subparagraph). Any EU country may also simply allow you to appoint one (Art. 204(1)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 204, paragraph 1Click opens the article on EUR-Lex., first subparagraph). From 1 July 2028 it is no longer a choice for a parcel up to EUR 150 sold without IOSS: a seller established outside the EU, in a country that has such an instrument with neither the EU nor the country of import, must appoint a tax representative there, for the import VAT and the VAT on those sales (Council Directive (EU) 2025/1539, Art. 1(1), new Article 201(3); Art. 1(3)(b)). This is separate from the IOSS intermediary. The countries, the duties and the joint liability are on fiscal representative.

What happens if you do nothing

The VAT is due whether or not you charged it. The destination country can assess the VAT you did not declare, and each EU country sets its own interest and penalties for a missing registration or a late return. A business that persistently breaks the OSS or IOSS rules is excluded from the scheme (Art. 369eDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369eClick opens the article on EUR-Lex., Art. 369rDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369rClick opens the article on EUR-Lex.), and is left with a registration in each country instead. Without IOSS, until 30 June 2028, your customers meet the import VAT at their door (Art. 369zDirective 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 369zClick opens the article on EUR-Lex.); from 1 July 2028 you owe it yourself (Council Directive (EU) 2025/1539, Art. 1(1)).

What you can skip

The invoice shows both VAT numbers and the exemption reference (Art. 226Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 226Click opens the article on EUR-Lex., points (3), (4) and (11)). Miss the EC Sales List entry and the exemption can fall: it “shall not apply where the supplier has not complied with the obligation provided for in Articles 262 and 263 to submit a recapitulative statement” (Art. 138(1a)Directive 2006/112/EC, the VAT Directive (consolidated text of 14 April 2025)Article 138, paragraph 1aClick opens the article on EUR-Lex.).