EU VAT for non-EU sellers explained
EU VAT guide for non-EU merchants on distance sales thresholds, establishment triggers, invoice fields, IOSS vs OSS decisions, marketplace rules, and audits.
EU VAT for non-EU sellers
This guide unpacks EU VAT obligations for non-EU e-commerce sellers—distance sales, fixed establishments, and invoice requirements. Treat this as guidance only; consult local advisors before filing. Use the EU VAT & IOSS Checker to generate your first readiness report.
Keep every assumption logged inside the Readiness Check so finance, ops, and tax partners are aligned.
When in doubt between IOSS, OSS, or local registrations, compare with the IOSS vs OSS decision guide.
| Question | Quick answer | Next action | Linked resource |
|---|---|---|---|
| Are consignments ≤ EUR 150 from outside EU? | Use IOSS | VAT/IOSS Checker | |
| Do you store goods in EU? | Register local VAT + OSS | EU compliance checklist | |
| Do marketplaces collect VAT? | Maybe—keep proof | EU compliance FAQ | |
| Need invoice fields? | See annex table below | EU market quick start |
Distance sales landscape
EU-wide EUR 10k threshold
Pre-threshold
Indicators
Actions
- Charge VAT from your “home” member state (if any) or local indirect tax when below EUR 10k/year.
- Monitor aggregated EU sales monthly; hitting EUR 8k is a signal to prep OSS paperwork.
Post-threshold
Indicators
Actions
- Choose between OSS or local VAT; OSS covers B2C intra-EU shipments from a single member state.
- When storing goods in multiple countries, you still need each local VAT ID alongside OSS.
Marketplace deemed-supplier rules
When platforms collect VAT
Platforms
Examples
- Amazon, eBay, Etsy, and Zalando often collect VAT for B2C sales where they’re deemed suppliers.
- You must still store VAT invoices for returns or audits even if marketplaces remit tax.
When you remain liable
Platforms
Examples
- Custom websites, Shopify, WooCommerce, and niche marketplaces leave VAT liability with you.
- Marketplaces may shift liability if you store inventory in the EU, so check contracts quarterly.
Fixed establishment triggers
Storage and personnel
Physical assets
Signals
Evidence
- EU warehousing (FBA, 3PL, micro-fulfillment) implies fixed establishment.
- Local staff (customer support, returns centers) can create taxable presence.
Actions
Evidence
- Register for local VAT where inventory resides before first intra-country sale.
- Align SKUs to each VAT number to simplify Intrastat filings.
Mixed fulfillment models
Own store + marketplace
Considerations
Checklist
- When Amazon stores goods in DE/PL but you sell via Shopify too, you still need DE/PL VAT IDs.
- Use OSS for intra-EU transfers while marketplaces manage their portion.
Dropship + print-on-demand
Considerations
Checklist
- Dropshipping from EU-based suppliers likely triggers VAT once you’re the seller of record.
- Print-on-demand partners may require your VAT ID to issue compliant invoices.
Invoice requirements
Mandatory fields
Core items
Details
Notes
- Supplier name, address, VAT ID.
- Customer name and address (B2C), VAT ID (if B2B).
Tax data
Notes
- Invoice date, sequential number, supply date.
- Tax base, VAT rate, VAT amount by rate.
Optional but recommended
Logistics markers
Contents
Notes
- Shipping method, tracking ID, incoterms.
- Consignment value for IOSS shipments.
References
Contents
Notes
- OSS or IOSS identification numbers.
- Marketplace order ID if tax handled by platform.
VAT by scenario
| Scenario | VAT status | Recommended approach | Linked tool/doc |
|---|---|---|---|
| Ship from outside EU, no storage, orders ≤ EUR 150 | Eligible for IOSS | Register via intermediary, collect VAT at checkout | VAT/IOSS Checker |
| Ship from outside EU, no storage, orders >EUR 150 | Standard import VAT | Customer pays at border or seller uses DDP | IOSS vs OSS guide |
| Store goods in EU member state | Fixed establishment | Register local VAT + possibly OSS | EU compliance checklist |
| Marketplace collects VAT | Deemed supplier | Maintain evidence; marketplace remits | EU compliance FAQ |
| Mixed channels (store + marketplace) | Split liability | Sync VAT IDs across systems | EU market quick start |
Invoice control matrix
| Field | Why it matters | Applies to |
|---|---|---|
| VAT ID (seller) | Confirms authority to charge VAT | OSS, local VAT, marketplace releases |
| VAT ID (buyer) | Needed for B2B reverse charge | Wholesale or B2B marketplaces |
| Tax base + rate | Evidence for returns & audits | All invoices |
| Currency + FX source | Customs alignment | Cross-border orders |
| OSS/IOSS ID | Proof of scheme usage | Consignments covered by schemes |
Country-specific VAT triggers
Germany: FBA corridors and marketplace-heavy sellers
Germany is the most common first landing spot for non-EU sellers because Amazon stores inventory in DE/PL. That convenience also makes it the fastest way to create fixed establishment risk.
Storage in DE or PL
Evidence to collect
Steps
- Store FBA/3PL contracts and inbound shipment IDs to prove when inventory first entered Germany or Poland.
- Map SKUs to warehouse codes so your VAT filings reconcile to stock movements.
Marketplace settlements and ELSTER
What to file
Steps
- Use ELSTER for German VAT returns even when marketplaces remit part of the tax—returns still need your ID and revenue figures.
- Keep marketplace payout reports as backup when reconciling OSS vs local VAT numbers.
France: eco-fees + VAT interactions
France ties packaging eco-fees and Triman marking to your VAT identity, so operations, finance, and legal must stay aligned.
Packaging and DSA bundle
Risks
Actions
- The same legal entity that owns the French eco-organisme contract should appear on invoices to avoid rejections.
- Keep Triman icon proofs and receipts with your VAT archive as DSA audits often request them together.
Cross-border flows
Risks
Actions
- Shipping from BE/NL into FR still counts toward OSS thresholds; do not assume marketplaces cover every SKU.
- Mirror French disclosures across Shopify/Woo/marketplaces using the snippet in French & German packaging.
Netherlands and Belgium: logistics hubs
NL/BE ports are popular consolidation hubs, which can quietly trigger local VAT if you stage inventory there before EU-wide fulfillment.
Temporary storage
Signals
Evidence
- Temporary bonded storage can still create VAT obligations if goods are sold while staged.
- Keep customs warehouse records and link them to OSS filings when goods move onward.
Triangulation setups
Signals
Evidence
- If you import via NL/BE and deliver to DE/FR consumers, you likely need NL/BE VAT plus OSS for cross-border shipments.
- Document Incoterms with freight forwarders; they influence who is the importer of record.
Common mistakes and audit defenses
Relying on marketplace emails as proof
Why it fails
Evidence gaps
Fixes
- Auditor expectations: PDF contracts or platform dashboards showing VAT responsibility per SKU, not just email confirmations.
- Export marketplace tax reports monthly; store alongside OSS filings for three-year retention.
Using customs value instead of intrinsic value for IOSS
Impact
Evidence gaps
Fixes
- IOSS eligibility hinges on intrinsic value (goods only). If you include shipping/insurance, you may exceed EUR 150 incorrectly.
- Add a data check in your ERP to calculate intrinsic value separately and flag orders that slip above EUR 150.
No mapping between VAT IDs and SKUs
Impact
Evidence gaps
Fixes
- Without a SKU-to-VAT-ID map, refunds and credit notes fail during audits because authorities cannot trace which VAT number collected the tax.
- Maintain a simple lookup table and sync it to Shopify tax overrides, Woo tax classes, and your warehouse management system.
Systems and automation blueprint
Shopify, WooCommerce, and ERP alignment
Tax settings
Steps
Owners
- Shopify: enable multi-origin shipping and apply per-country tax overrides that match your VAT ID map.
- WooCommerce: use OSS plugins plus country-specific classes; ensure store currency conversion updates daily.
Checkout and invoicing
Steps
Owners
- Inject IOSS/OSS/local VAT IDs onto invoices and packing slips; use the template from EU market quick start.
- For B2B flows, collect VAT IDs at checkout and validate via VIES before applying reverse charge.
Data warehouse and monitoring
Threshold dashboards
Steps
Owners
- Build a rolling 12-month EU revenue chart and a EUR 8k pre-threshold alert so finance can pre-file OSS.
- Split reporting by consignment value buckets (≤ EUR 150 vs >EUR 150) to track IOSS eligibility drift.
Evidence vault
Steps
Owners
- Store VAT filings, marketplace tax reports, and consent logs from GDPR basics in tamper-proof storage.
- Align retention periods to the strictest member state you sell into (often six to ten years).
Monitoring cadence
Daily
Revenue watch
Owners
Checklist
- Finance tracks EU revenue vs EUR 10k threshold.
- Ops flags consignments near EUR 150 to avoid misusing IOSS.
Refunds & adjustments
Owners
Checklist
- Support reviews refunds to ensure VAT adjustments recorded.
- Accounting reconciles VAT collected vs payment provider payouts.
Weekly
Filing prep
Owners
Checklist
- Tax team reviews intermediary dashboards for IOSS submissions.
- Logistics shares new EU storage locations for VAT updates.
Documentation
Owners
Checklist
- Archive invoices in tamper-proof storage by VAT number.
- Update SOPs with cross-links to GDPR basics and French & German packaging when legal notices change.
Next steps
- Run the Readiness Check for your scenario → Start now
- Use the EU VAT & IOSS Checker → Open tool
- Share this guide with finance / ops teammates.
FAQ
Do non-EU Shopify or WooCommerce sellers need IOSS for orders under EUR 150?
Yes—if consignments ship from outside the EU, stay at or below EUR 150 intrinsic value, and you are the seller of record. Register via an intermediary if you lack an EU entity, charge destination VAT at checkout, and display the IOSS ID on invoices and labels. Keep eligibility checks in your ERP so mixed baskets or shipping charges that push value over EUR 150 are rerouted to import VAT.
Can I use OSS if I store inventory in multiple EU countries?
OSS covers cross-border B2C sales but never replaces local VAT where you store goods. You must hold VAT IDs in each storage country and reconcile OSS filings against those local returns. Map SKUs to VAT IDs, ensure invoices show the correct registration per shipment, and keep warehouse movement logs aligned to filings.
What evidence should I keep when marketplaces claim to collect VAT?
Retain marketplace contracts and monthly payout or tax reports showing deemed-supplier treatment per SKU. Keep them alongside OSS and local VAT filings for at least three years. Even if platforms collect VAT, your direct store must maintain its own VAT IDs, and you need proof to avoid double-charging or gaps during audits.
How do I keep IOSS eligibility when shipping near EUR 150?
Calculate intrinsic value separately from shipping and insurance. Add checkout or ERP checks that flag orders drifting above EUR 150 and route them to import VAT instead of IOSS. Log every decision with order IDs, values, and applied VAT scheme so auditors can see why an order was included or excluded.
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