EU VAT Representative for Non-EU Businesses: Country Guide

A non-EU business needs a VAT (fiscal) representative only where a member state requires one for what it does there. Hungary, Portugal and Romania require one from every non-EU business; Denmark, Estonia, France and Poland require one unless your country is on their exemption list (Poland exempts Norway and the United Kingdom); Germany allows one only for exempt import-and-resupply cases; Czechia, Finland, Ireland, Latvia, Malta and Slovakia have no general requirement. Under Art. 204 of the VAT Directive a state may demand a representative only where no mutual-assistance instrument exists with your country, and sellers of parcels up to EUR 150 need an EU intermediary for IOSS unless they ship from Norway. Logistivo's free atlas compares all 27 states for your home country and activity, with the legal basis and the official page for each.

Source: Publications Office of the European Union (CELLAR copy of EUR-Lex) · Publications Office of the European Union (CELLAR) · European Commission, One Stop Shop portal · HM Revenue & Customs · Generalzolldirektion (German customs). Data last updated: 8 November 2026.

Which EU countries require a VAT representative from your business?

• Which EU countries require a VAT representative from your business? — Choose where your company is established and what you do in the EU. The atlas colours all 27 member states (representative required, exempt, optional, direct registration) and shows the legal basis and the official page for each.
• This page is for businesses established outside the EU, such as sellers, importers, forwarders and carriers, that sell, store or import goods in the EU. A member state cannot force an EU-established business to appoint a VAT representative. It covers VAT representation; customs representation is a separate role explained below.
• Where is your company established? — The country of your registered seat decides whether a mutual-assistance exemption can apply. Art. 204(1) Directive 2006/112/EC
• What do you do in the EU? — Four routes: IOSS parcels, stock in the EU, import with onward supply (procedure 42/63), and business customers only. Art. 143(2), 196, 204, 369l-369m Directive 2006/112/EC
• EU member states (tap a country) — Each tile is a member state; the card shows its rule. national VAT laws, see the ledger
• Country-by-country ledger — Each row states the national rule and its legal basis. Where an official exemption list is not published or the source could not be read, the row says so instead of guessing.
• Austria — A VAT representative is mandatory unless a mutual-assistance arrangement with the business's country applies; no official list is published, so confirm with the tax authority. The ordinance that should name such countries could not be found, so no origin can be confirmed as exempt. A tax adviser, lawyer, notary or forwarder can act, or an entrepreneur approved by the tax office; the representative must also accept service of documents. Users of the non-Union OSS are excluded. — § 27 (7)–(9) UStG 1994
• Belgium — A VAT representative is mandatory unless a mutual-assistance arrangement with the business's country applies; no official list is published, so confirm with the tax authority. An individual representative posts a bank guarantee; a pre-approved global representative can act for specific operations such as import or a VAT warehouse. For the United Kingdom the tax authority describes a temporary tolerance (direct identification kept) pending the Commission's position; the page is undated, so confirm it is still applied. — Art. 55 VAT Code (Wetboek BTW)
• Bulgaria — Could not be verified from an official source for this review; confirm the rule with the tax authority before relying on this entry. The National Revenue Agency's website was not readable from our server. Ask the agency or a Bulgarian adviser.
• Croatia — A VAT representative is mandatory unless a mutual-assistance arrangement with the business's country applies; no official list is published, so confirm with the tax authority. The tax administration states the duty without the mutual-assistance condition, so assume it applies. The representative must be VAT-registered in Croatia, cannot be a branch, and is liable as guarantor-payer. Users of the non-Union OSS are excluded. — Art. 126 ZPDV; Art. 194 Pravilnik o PDV-u
• Cyprus — A representative is required only when the tax authority directs it. Cyprus requires a VAT representative only when the Commissioner directs one (non-EU persons without a mutual-assistance provision); if you do not comply the Commissioner may demand a guarantee. The tax department says a representative or a guarantee is expected of non-EU registrants. The representative is jointly and severally liable. — s. 37 VAT Law 95(I)/2000
• Czechia — No VAT representative is required: the business registers directly. Czechia has no fiscal representative for non-EU businesses, but since 1 January 2025 a business with no seat or establishment in the EU must appoint a delivery agent with a Czech data box (unless it has its own data box); failure is fined CZK 1,000 per day. The agent is not liable for the VAT. — ss. 4(1)(g), 96(3), 98a–98b ZDPH (Act 235/2004)
• Denmark — A VAT representative is mandatory unless the business is established in a country named in the official list: Faroe Islands, Greenland, Iceland, Norway, United Kingdom, Isle of Man, and Åland Islands. The United Kingdom and the Isle of Man count as approved only while the EU-UK trade agreement applies; Gibraltar, Jersey and Guernsey are not approved. The representative and the business are jointly liable. No representative is needed where the customer accounts for the VAT. — § 47 stk. 2, § 46 momsloven; D.A.14.1.5
• Estonia — A VAT representative is mandatory unless the business is established in a country named in the official list: Norway and United Kingdom. The exemption applies since 1 January 2022. The representative must hold a licence from the tax board, which may ask it for security. — Taxation Act (MKS) § 8¹; KMS § 20(6)
• Finland — No VAT representative is required: the business registers directly. Import and onward supply (procedure 42/63): Not verified Finland requires a representative only if a foreign trader applies voluntarily for VAT liability, and then unless it is established in another EU state or a country with an equivalent mutual-assistance instrument (the tax authority names Norway). Mandatory registrations are direct. The representative is not liable for the tax. For procedure 42/63 the sources do not say in one sentence which route applies. — AVL (1501/1993) §§ 9, 12, 173 a
• France — A VAT representative is mandatory unless the business is established in a country named in the official list: South Africa, Antigua & Barbuda, Armenia, Aruba, Australia, Azerbaijan, Bosnia & Herzegovina, Cape Verde, Curaçao, Dominica, Ecuador, Georgia, Ghana, Grenada, Greenland, Cook Islands, Faroe Islands, India, Iceland, Jamaica, Japan, Kenya, Kuwait, North Macedonia, Mauritius, Mexico, Moldova, Nauru, Niue, Norway, New Zealand, Pakistan, French Polynesia, South Korea, United Kingdom, St. Barthélemy, St. Martin, Sint Maarten, Tunisia, Türkiye, Ukraine, and Vanuatu. France exempts businesses established in one of the countries on the DGFiP list (42 countries, page updated 28 February 2025). The one-off representative regime was abolished on 1 January 2025 (tolerated until 31 December 2025). A mandataire acting in your name is optional and does not replace a representative. — CGI art. 289 A
• Germany — No VAT representative is required: the business registers directly. Import and onward supply (procedure 42/63): Optional Germany allows a fiscal representative (voluntary) only if you make exclusively tax-exempt supplies in Germany and cannot deduct input VAT, typically an import followed by an intra-EU supply under procedure 42/63. With any taxable German supply, such as sales from a German warehouse, you register in your own name. Since 1 September 2026 the permitted representatives are those named in section 22a(2) UStG (tax advisers, lawyers and similar professionals, forwarders and other customs representatives under section 4d StBerG). — §§ 22a–22e UStG; § 5 Abs. 1 Nr. 3 UStG
• Greece — Could not be verified from an official source for this review; confirm the rule with the tax authority before relying on this entry. The tax authority's website was not readable from our server. Ask the authority or a Greek adviser.
• Hungary — A VAT representative is mandatory for every non-EU business that has to register for VAT; no exemption by country of establishment is provided. Hungary requires a financial representative from every non-EU business that is itself liable for the tax, with no exemption by country; users of the OSS and IOSS schemes are excluded, and where the Hungarian customer accounts for the VAT no representative is needed. The representative must be a limited-liability or joint-stock company with at least HUF 150 million subscribed capital or an equivalent bank guarantee in its own name, and it is jointly and severally liable with you. — Art. 148–149 Áfa tv. (Act CXXVII of 2007); Art. 20 Air. (Act CLI of 2017)
• Ireland — No VAT representative is required: the business registers directly. Ireland has no general duty to appoint a representative: non-established traders register directly. Since 19 December 2020 the Revenue Commissioners can serve a written notice requiring a representative established in the EU, but only where no mutual-assistance instrument exists with your country; the representative is then jointly and severally liable. Users of the non-Union OSS are excluded. — s. 109A VAT Consolidation Act 2010 (Finance Act 2020 s. 41)
• Italy — A VAT representative is mandatory unless a mutual-assistance arrangement with the business's country applies; no official list is published, so confirm with the tax authority. Direct identification (art. 35-ter) is open only to EU businesses and to countries with a mutual-assistance instrument, so most non-EU businesses use a representative, who is jointly liable and gives a guarantee in the bands of the decree of 9 December 2024. If you sell only to Italian VAT-registered customers, the reverse charge applies and no registration arises (art. 17). The rules move to the VAT consolidated act on 1 January 2027. — Art. 17 and 35-ter DPR 633/1972 (arts. 64, 70 TU IVA from 1.1.2027)
• Latvia — No VAT representative is required: the business registers directly. Import and onward supply (procedure 42/63): Optional Latvia has no general duty to appoint a representative: a third-country business registers with the State Revenue Service itself or through an authorised domestic person. An optional "fiscal representative" regime exists for import followed by onward supply and similar transactions (the procedure 42 case); if you are represented that way you need not register. That representative must be a long-registered Latvian taxpayer that pays the VAT for you and lodges security. The consolidated VAT law could not be read, so this rests on the Revenue Service's pages and the original 2012 text: confirm. — Art. 1(5), 56, 63, 65 VAT Law (Pievienotās vērtības nodokļa likums)
• Lithuania — Could not be verified from an official source for this review; confirm the rule with the tax authority before relying on this entry. The tax authority's and the legal database's websites were blocked from our server. Ask the State Tax Inspectorate or a Lithuanian adviser.
• Luxembourg — Could not be verified from an official source for this review; confirm the rule with the tax authority before relying on this entry. The legal database could not be read. The business portal says non-established businesses with taxable supplies must register for VAT and does not mention a representative; that silence is not evidence. Ask the tax administration.
• Malta — No VAT representative is required: the business registers directly. Malta has no duty to appoint a representative before registering, but the Commissioner can designate a Malta-resident customer, agent or other counterparty as your representative; that person is jointly and severally liable. How the Commissioner applies this in practice could not be verified. — Arts. 10(4), 63(5), 66 VAT Act (Cap. 406)
• Netherlands — A VAT representative may be appointed; direct registration is also possible. A representative is mandatory for non-EU businesses with Dutch-taxable distance sales (unless they use the Union or import scheme) and for excise goods and some zero-rated bulk goods; otherwise it is optional. Only a representative can obtain the article 23 permit that defers import VAT. The guarantee is 5% of the average monthly VAT, at least EUR 5,000. — Wet OB 1968 art. 23, 2a; Belastingdienst
• Poland — A VAT representative is mandatory unless the business is established in a country named in the official list: Norway and United Kingdom. For an import followed by an intra-EU supply, article 18d lets the representative act in its own name, so you need not register for VAT in Poland. The exemption comes from the regulation of 23 February 2021. — Art. 18a–18d ustawy o VAT; Dz.U. 2021 poz. 347
• Portugal — A VAT representative is mandatory for every non-EU business that has to register for VAT; no exemption by country of establishment is provided. Every non-resident without a seat, establishment or domicile in another EU state must appoint a representative (art. 30 CIVA); there is no mutual-assistance exemption. The representative is the debtor of the tax and the represented business is jointly liable. — Art. 30 CIVA
• Romania — A VAT representative is mandatory for every non-EU business that has to register for VAT; no exemption by country of establishment is provided. Non-EU businesses must register for VAT through a representative; only one representative is allowed for all operations in Romania. EU-established businesses can choose direct registration or a representative. — Art. 316(7) Codul fiscal; norme pct. 88–89
• Slovakia — No VAT representative is required: the business registers directly. Import and onward supply (procedure 42/63): Optional Slovakia has no general representative: foreign businesses register directly. An optional representative exists only for the import exemption followed by an intra-EU supply (art. 69a); the importer represented that way need not register. — Art. 5 and 69a Act 222/2004; Art. 48(3), 48b
• Slovenia — A VAT representative is mandatory unless a mutual-assistance arrangement with the business's country applies; no official list is published, so confirm with the tax authority. Slovenia requires a tax representative of third-country businesses; the tax administration names three exceptions: the non-Union OSS, occasional international road passenger transport, and a country with an EU-level mutual-assistance agreement. For procedure 42/63 a third-country business must be VAT-identified and appoint a representative. The administration's pages are not fully consistent, so confirm. — Art. 76 ZDDV-1
• Spain — A VAT representative is mandatory unless a mutual-assistance arrangement with the business's country applies; no official list is published, so confirm with the tax authority. Users of the special distance-sales regimes (OSS and IOSS) need no representative, and a business established in another EU state never does. A separate resident representative is needed to claim a VAT refund (art. 119 bis). — Art. 164.Uno.7.º Ley 37/1992; art. 82 RD 1624/1992
• Sweden — A VAT representative is mandatory unless a mutual-assistance arrangement with the business's country applies; no complete official list is published (named in the sources: Norway, Iceland, Faroe Islands, and Greenland). The guidance names the Nordic agreements but not the United Kingdom or Switzerland. The agent is not liable for the VAT. — Ch. 6 ss. 2–3 skatteförfarandelagen (2011:1244)
• Keep the importer, customs agent, carrier and documents on one load — In Logistivo you add the importer, the customs agent and the carrier as named participants on a load, and the load owner decides who sees what. Upload the commercial invoice, the CMR and the customs declaration to the load chat: AI recognises the document type, compares packages and gross weight between the invoice and the transit document, and flags differences. Messages and documents are translated automatically between 42 languages.
• Load Management — Named participants, controlled visibility, documents and a translated chat on every load. — /en/load-management
• Customs Intelligence — HS code, import duty, anti-dumping measures and, for EU destinations, import VAT in one query. — /en/customs-intelligence
• Importer, customs agent and documents on one load — With a free Logistivo account you name the importer, the customs agent and the carrier on the load, keep the invoice, declaration and CMR on it, and write to each party in your own language.
• General information, not tax or legal advice. National rules change; confirm with the member state's tax authority or a licensed adviser before you appoint a representative or register.
• Load Management · Customs Intelligence

Fiscal representative, direct VAT registration, IOSS intermediary, customs representative: what is the difference?

• Fiscal representative, direct VAT registration, IOSS intermediary, customs representative: what is the difference? — Four different roles are often called "representative". Appointing the wrong one does not solve the VAT or customs question you actually have.
• VAT (fiscal) representative — What it does: Registers you for VAT in a member state, files its VAT returns and is the person liable for the tax. Art. 204 of the VAT Directive lets a state allow one, and require one where no mutual-assistance instrument exists with your country. | Who needs it: Non-EU businesses with taxable activity in a state that requires one, or that choose one. | Who is liable: Set by national law; Art. 205 lets a state make another person jointly and severally liable (see the liability chapter).
• Direct VAT registration — What it does: You obtain a national VAT number in your own name. A state may still ask for security or a delivery agent (Czechia). | Who needs it: Where no representative is required or your country is exempt. | Who is liable: You alone.
• IOSS intermediary — What it does: An EU-established person who registers you for the Import One Stop Shop, files the monthly return and pays the VAT on consignments up to EUR 150 (Art. 369l and 369m). | Who needs it: Non-EU sellers using IOSS, except sellers shipping from Norway. | Who is liable: Appointed as the person liable for the VAT under the scheme (Art. 369l(2)).
• Customs representative — What it does: Lodges customs declarations for you. A declarant must be established in the EU (Art. 170(2) Union Customs Code); a direct representative acts in your name, an indirect one in its own name on your behalf (Art. 18). | Who needs it: Non-EU importers and exporters whose goods need a customs declaration. | Who is liable: From 21 September 2027 an indirect representative of a non-EU importer is treated as the importer (Regulation (EU) 2026/2108, Art. 33(3)).
• Source: Directive 2006/112/EC, Art. 204, 205, 369l; Regulation (EU) No 952/2013, Art. 18 and 170; Regulation (EU) 2026/2108, Art. 33.

Which of the four routes is yours?

• Consumer parcels up to EUR 150: IOSS — Register for IOSS through an EU intermediary (not needed from Norway). VAT is collected at checkout and declared monthly; EU law provides for the intermediary here, not for a national fiscal representative. From 1 July 2026 a flat EUR 3 customs duty per item applies.
• Stock in an EU warehouse: a local VAT number — Goods held in a member state mean a VAT registration there, and the state's representative rule applies (see the map). Cross-border consumer sales from that stock can go through the Union One Stop Shop, whose member state of identification is where dispatch begins.
• Import, then supply a business in another state: procedure 42/63 — The import VAT is exempted if you give the importing state's VAT number (yours or your representative's), your customer's VAT number in the destination state and proof of transport. That VAT number is where the representative rule bites.
• Only VAT-registered business customers: usually nothing — Services to a business are taxed where the customer is established and the customer accounts for the VAT (Art. 44 and 196). A state may do the same for goods (Art. 194). A supplier that sells only this way can often do without a VAT number and so without a representative.

What does the import declaration for procedure 42/63 need?

• What does the import declaration for procedure 42/63 need? — Procedure code 42 releases non-EU goods for free circulation with the import VAT exempted when they move on to a customer in another member state; code 63 is used for re-imported goods. Art. 143(1)(d) and (2) of the VAT Directive set the conditions.
• A VAT number of the importing state: yours or your representative's — At the time of import you must provide your VAT number issued in the member state of importation, or that of your tax representative who is liable for the VAT there (Art. 143(2)(a)). This is where the national representative rule decides whether you can use the procedure alone.
• The VAT number of your customer in the other member state — You also provide your customer's VAT number issued in another member state, or your own number there when you move your own goods (Art. 143(2)(b)). Check it in VIES before the goods move. VAT number checker
• Evidence that the goods move on — You give evidence that the goods are to be transported or dispatched from the importing state to another member state; a state may allow this evidence to be shown only on request (Art. 143(2)(c)).
• A declarant established in the EU — The customs declaration must be lodged by a person established in the Union, with narrow exceptions (Art. 170(2) and (3) of the Union Customs Code), so a non-EU importer uses a direct or indirect customs representative. In specific cases a non-EU operator registers for an EORI number where it first lodges a declaration (Art. 9(2)). EORI number checker
• The code and the national paperwork — The declaration carries code 42 (63 for re-imports) and the VAT numbers. Some states ask for more: Germany, for example, requires the representative's VAT number and tax office and the buyer's details in the declaration (German customs, fiscal representation page).
• VAT number checker · EORI number checker

How is a VAT representative liable, and what does it cost?

• Art. 205 of the VAT Directive lets a state make a person other than the taxable person jointly and severally liable. States use this differently. In Denmark, Croatia, Cyprus, Malta, Poland, Portugal and Italy the representative and the business are jointly liable; in Sweden and Finland the representative is not liable for the tax; in the Netherlands the liability under a general permit is capped each year at the guarantee, while under a limited permit it covers the whole tax; Slovakia's optional import representative takes over the importer's rights and obligations to the extent of its power of attorney.
• Fees are a matter of contract, not law, and we do not quote them. What the law does set: in the Netherlands a guarantee of 5% of the average monthly VAT, at least EUR 5,000 (at most EUR 100,000 for bulk goods and EUR 500,000 for other goods); in Italy guarantee bands starting at EUR 30,000 for a representative acting for two to nine businesses (decree of 9 December 2024; a single principal makes a declaration instead); in Belgium a bank guarantee from an individual representative; in Estonia and Finland security on the authority's demand. Because a representative can answer for your VAT, read the contract for security, indemnity and the end of the mandate before you sign.
• Customs liability is separate. An indirect customs representative acts in its own name under Art. 18 of the Union Customs Code; from 21 September 2027 the new Customs Code treats an indirect representative of a non-EU importer as the importer (Regulation (EU) 2026/2108, Art. 33(3)).

Why are EU and non-EU businesses treated differently?

• Can a state require a representative? — Business established in the EU: No. Art. 204 lets a state only allow an EU business to appoint one. — Business established outside the EU: Yes, where no mutual-assistance instrument exists with your country (Art. 204(1), second subparagraph); each state decides, and many do.
• EUR 10,000 distance-sales threshold — Business established in the EU: A seller established in only one state can keep taxing below EUR 10,000 at home (Art. 59c). — Business established outside the EU: No threshold applies to a supplier established outside the EU (Commission explanatory notes, 3.2.7).
• Union One Stop Shop — Business established in the EU: Register for the OSS in the state of establishment. — Business established outside the EU: Available once you hold a VAT number; the state of identification is where dispatch begins (Art. 369a(2)), and it may still require a representative.
• IOSS (consignments up to EUR 150) — Business established in the EU: Direct registration; an intermediary is optional. — Business established outside the EU: An EU intermediary is mandatory unless you ship from Norway (Art. 369m(1); Implementing Decision (EU) 2021/942 lists only Norway).

What changes between 2026 and 2028?

• 1 July 2026 — The EUR 150 customs-duty relief ends. A flat EUR 3 duty per item applies to distance sales of imported goods in consignments up to EUR 150 until 30 June 2028 (Council Regulation (EU) 2026/382; Commission explanatory notes, addendum of 6 October 2026).
• 1 November 2026 — The Union handling fee of EUR 2 per item applies to distance sales of imported goods (Delegated Regulation (EU) 2026/2152; Regulation (EU) 2026/2108, Art. 20(2)). The Commission treats it as part of the VAT taxable amount (addendum of 6 October 2026).
• 1 January 2027 — The first changes of the ViDA package apply, including clarifications to the EUR 10,000 threshold and to refunds under the One Stop Shop schemes (Directive (EU) 2025/516, Art. 2).
• 21 September 2027 — The new Union Customs Code (Regulation (EU) 2026/2108) replaces Regulation (EU) No 952/2013. An indirect customs representative acting for a non-EU importer is treated as the importer (Art. 33(3)).
• 1 July 2028 — The VAT Directive's new Art. 194 makes the customer liable when a supplier that is neither established nor identified in the state supplies a customer already identified there (Directive (EU) 2025/516). Directive (EU) 2025/1539 applies: a non-EU supplier of imports up to EUR 150 that does not use IOSS, and is not from Norway or a country with a mutual-assistance agreement with the importing state, must appoint a tax representative in the member state of importation.

Your home system: United Kingdom, Northern Ireland, the Gulf, India and the United States

• Export proof at home, a third-country seller in the EU — On the UK side, exports are zero-rated if you hold evidence of export within the time limits: three months to export and three months to obtain evidence (HMRC VAT Notice 703). On the EU side Great Britain is a third country: IOSS needs an intermediary (HMRC's own guidance says so), and the VAT protocol of the EU-UK trade agreement is not on the IOSS list. Denmark, Estonia, France and Poland name the UK as exempt from the representative requirement; Portugal and Romania do not. Check state by state in the atlas.
• For goods, inside the EU VAT system — Under the Windsor Framework Northern Ireland applies EU VAT rules to goods (Withdrawal Agreement, Protocol Art. 8 and Annex 3). HMRC treats sales to EU VAT-registered customers as intra-EU supplies, and consumer sales above EUR 10,000 can go through the OSS Union scheme. Services follow Great Britain's rules.
• No VAT mutual-assistance agreement with the EU — The EU's IOSS list names Norway only, so a member state may require a representative from your business where its law does. The OECD multilateral convention on tax assistance is a different instrument: India (in force 2012) and the UAE (2018) are parties and the United States is a party to the original convention (1995), but no source we found says a member state treats it as the legal instrument of Art. 204. The UAE's export zero-rating needs a customs declaration and shipping evidence, and the goods must leave within 90 days of the supply (Federal Decree-Law 8 of 2017, Art. 45(1); Executive Regulation, Art. 30).

Three worked examples

• A Manchester seller ships garden tools to shoppers — Each order is below EUR 150, so the seller can use IOSS. Great Britain is not on the EU list of countries with a mutual-assistance agreement, so it must appoint an EU intermediary. VAT is charged at checkout and declared in the monthly IOSS return; no national fiscal representative is involved. From 1 July 2026 a flat EUR 3 duty per item applies. At home it keeps the export evidence for the UK zero-rating.
• A Belfast machine maker sells to a company and to consumers — Goods leaving Northern Ireland follow EU VAT rules. The sale to a French company with a VAT number is a zero-rated dispatch with proof of removal, and the customer accounts for the VAT. Consumer sales above EUR 10,000 can be reported through the OSS Union scheme instead of registering in each country.
• A US brand imports pallets through Rotterdam and supplies two distributors — The import VAT can be exempted under procedure 42 if the brand gives a Dutch VAT number (its own or its representative's), the two distributors' VAT numbers in Belgium and Germany, and proof of transport. In the Netherlands a representative is optional, but only a representative can obtain the article 23 permit that defers import VAT. A declarant established in the EU lodges the customs declaration.

Six mistakes that cost non-EU businesses money

• Appointing a representative where none is needed — An EU-established business, a business from an exempt country and a seller who only supplies VAT-registered customers usually need none. An unnecessary appointment adds a fee and a liability.
• Assuming one appointment covers customs and VAT — The VAT representative and the customs representative are separate mandates with separate rules; an indirect customs representative acts in its own name, a VAT representative registers and files for you.
• Using IOSS for consignments above EUR 150 or for excise goods — IOSS covers goods in consignments of up to EUR 150 and excludes excise goods (Art. 369l). Larger consignments follow the normal import VAT rules.
• Choosing the country by price instead of by where the goods are — Registration follows where goods are held or imported, and the state of identification for the Union OSS is where dispatch begins. Pick the state that matches your logistics, then read its representative rule.
• Ignoring the delivery term — Under DDP the seller clears the goods for import and carries the import taxes; under DAP the buyer does (Incoterms 2020). Settle who is the importer before you ask who needs a VAT number. Incoterms 2020 chart
• Trusting an undated list — National exemption lists change: France's list on the tax authority's page was updated on 28 February 2025, and Denmark counts the UK only while the EU-UK trade agreement applies. Check the official page shown in the ledger on the day you decide.
• Incoterms 2020 chart

Where Logistivo helps with these flows

• One file for importer, customs agent, carrier and representative — Add each party as a named participant (sender, receiver, carrier, organiser, customs agent) and let the load owner decide who sees what. Keep the commercial invoice, CMR and customs declaration on the load and write in the load chat: messages and documents are translated between 42 languages. Load Management
• Duty and import VAT before the shipment moves — One Customs Intelligence query shows the HS code, import duty and anti-dumping measures from official sources; for EU destinations it also shows import VAT at the destination state's standard rate from the European Commission's TEDB database. Each query is archived as it stood that day. Customs Intelligence
• VAT numbers and invoices in one place — Check up to ten EU VAT numbers at once in VIES before you invoice without VAT, then keep the verified number on the company card that your invoices and e-invoices (UBL BIS 3.0, Factur-X, XRechnung) use. VAT number checker · Accounting & e-Invoicing
• Your customs agent on the same load — Customs agents join the load as participants with the same documents and chat, so the declaration, invoice and transport papers stay together. Estimate the import VAT of a shipment with the import VAT calculator.
• Load Management · Customs Intelligence · VAT number checker · Accounting & e-Invoicing · import VAT calculator

Source

• Publications Office of the European Union (CELLAR copy of EUR-Lex) — Council Directive 2006/112/EC on the common system of VAT, consolidated text (Art. 44, 143, 194, 196, 201, 204, 205, 358a, 359, 369a, 369l, 369m) — https://publications.europa.eu/resource/celex/02006L0112-20250414
• Publications Office of the European Union (CELLAR) — Council Directive (EU) 2025/516 (VAT in the Digital Age) — https://publications.europa.eu/resource/celex/32025L0516
• Publications Office of the European Union (CELLAR) — Council Directive (EU) 2025/1539 (tax representative for non-IOSS distance sales of imported goods, from 1 July 2028) — https://publications.europa.eu/resource/celex/32025L1539
• Publications Office of the European Union (CELLAR) — Commission Implementing Decision (EU) 2021/942 (list of third countries with a mutual-assistance agreement: Norway) — https://publications.europa.eu/resource/celex/32021D0942
• Publications Office of the European Union (CELLAR) — Council Regulation (EU) 2026/382 (elimination of the EUR 150 customs-duty relief) — https://publications.europa.eu/resource/celex/32026R0382
• Publications Office of the European Union (CELLAR) — Regulation (EU) 2026/2108 establishing the Union Customs Code and the EU Customs Authority — https://publications.europa.eu/resource/celex/32026R2108
• Publications Office of the European Union (CELLAR) — Commission Delegated Regulation (EU) 2026/2152 (amount of the Union handling fee: EUR 2 per item, applies from 1 November 2026) — https://publications.europa.eu/resource/celex/32026R2152
• Publications Office of the European Union (CELLAR) — Regulation (EU) No 952/2013, Union Customs Code, consolidated text (Art. 9, 18, 19, 170) — https://publications.europa.eu/resource/celex/02013R0952-20221212
• European Commission, One Stop Shop portal — VAT e-commerce explanatory notes (revised for 1 January 2027) and addendum on the EUR 3 duty and EUR 2 handling fee (6 October 2026) — https://vat-one-stop-shop.ec.europa.eu/guides_en
• European Commission, One Stop Shop portal — Register to OSS: non-EU businesses, intermediaries and Norway — https://vat-one-stop-shop.ec.europa.eu/one-stop-shop/register-oss_en
• HM Revenue & Customs — Check if you can register for the VAT Import One Stop Shop scheme — https://www.gov.uk/guidance/check-if-you-can-register-for-the-vat-import-one-stop-shop-scheme
• HM Revenue & Customs — VAT on goods exported from the UK (VAT Notice 703) — https://www.gov.uk/guidance/vat-on-goods-exported-from-the-uk-notice-703
• HM Revenue & Customs — VAT on movements of goods between Northern Ireland and the EU — https://www.gov.uk/guidance/vat-on-movements-of-goods-between-northern-ireland-and-the-eu
• Generalzolldirektion (German customs) — Fiskalvertretung (procedure 42/63 and fiscal representation in Germany) — https://www.zoll.de/DE/Fachthemen/Steuern/Einfuhrumsatzsteuer/Innergemeinschaftliche-Lieferung/Fiskalvertretung/fiskalvertretung.html

Frequently asked questions

Do I need a VAT representative to sell to EU customers from outside the EU?

Only if the member state where you must register for VAT requires one for what you do there. A state can require a representative from a non-EU business where no mutual-assistance instrument exists with its country (Art. 204 of the VAT Directive), and many do; others let you register directly. If you sell only to VAT-registered businesses, or only parcels up to EUR 150 through IOSS, you usually need no national representative. The atlas shows the rule for each of the 27 states.

Which EU countries require a fiscal representative for non-EU companies?

In the states we could read in official sources: Hungary, Portugal and Romania require one from every non-EU business; Denmark, Estonia, France and Poland require one unless your country is on their list of exempt countries; Austria, Belgium, Croatia, Italy, Slovenia, Spain and Sweden require one unless a mutual-assistance arrangement with your country applies, without a complete published list; Cyprus requires one only when the Commissioner directs it; in the Netherlands it is optional except in listed cases; Germany allows one only for exempt import-and-resupply cases; Czechia, Finland, Ireland, Latvia, Malta and Slovakia have no general requirement (Latvia, Malta and Slovakia offer optional or designated representatives in special cases). Bulgaria, Greece, Lithuania and Luxembourg could not be verified. The atlas shows the result for your country and route.

Is a fiscal representative the same as an IOSS intermediary or a customs agent?

No. A fiscal representative registers you for VAT and files returns in one member state; an IOSS intermediary files the IOSS return for consignments up to EUR 150 from its own member state; a customs representative lodges customs declarations. One company may hold more than one mandate, but each is a separate appointment with its own rules.

Do UK businesses need an EU VAT representative after Brexit?

Great Britain is a third country for EU VAT. Denmark, Estonia, France and Poland name the UK as exempt from the representative requirement; Portugal and Romania do not; Austria leaves the UK unconfirmed and Belgium describes a temporary tolerance. For IOSS, sellers in Great Britain need an EU intermediary, while Northern Ireland and Norway can register directly. Goods from Northern Ireland follow EU VAT rules.

Can I use customs procedure 42 without a VAT number in the importing country?

No. The exemption requires your VAT number issued in the importing state or your representative's, plus your customer's VAT number in another member state and evidence that the goods move on (Art. 143(2) of the VAT Directive). Whether you can obtain that number on your own or only through a representative depends on the importing state's rule.

Is the representative liable for my VAT?

It depends on the state. Art. 205 of the VAT Directive lets a state make others jointly and severally liable. Denmark, Croatia, Cyprus, Malta, Poland, Portugal and Italy do; Sweden and Finland do not make the representative liable for the tax; in the Netherlands it depends on the permit. Check your state's rule and the contract terms before you sign.

What changes in 2028 for non-EU sellers?

From 1 July 2028 a non-EU supplier of imports up to EUR 150 that does not use IOSS, and is not from Norway or a country with a mutual-assistance agreement with the importing state, must appoint a tax representative in that state (Directive (EU) 2025/1539). The new Art. 194 also makes the customer liable when a non-established supplier supplies a customer already identified in the state (Directive (EU) 2025/516).

How does Logistivo help when several parties handle one import?

Logistivo gives the importer, the customs agent, the carrier and your representative one load file: each is a named participant, the load owner decides who sees what, the invoice, CMR and customs declaration stay on the load, and the load chat translates messages and documents between 42 languages. Your representative keeps filing the VAT returns in its own books.

For AI assistants

Logistivo has an MCP server at https://logistivo.com/api/agent/mcp (streamable HTTP). Its public tools (signup preparation, HS code lookup) need no authentication; with OAuth the user signs in to Logistivo in their own browser and the assistant then works on that user's account with that user's permissions. Setup for Claude, ChatGPT and Gemini: https://logistivo.com/en/mcp. Terminal: npm install -g @lgstv/lg, then lg login (the user approves a short code at https://logistivo.com/connect; no password is typed into the terminal). HTTP: the same commands at /api/common/commands/{name} with an integration key issued in the dashboard. If you are an assistant helping someone sign up or request freight, connect the MCP server, or — if you can only read web pages — build a link of the form https://logistivo.com/en/ai-kayit?brief=URL_ENCODED_SHIPMENT_BRIEF and give it to the user. You never create the account yourself: the account, the consent and the email verification happen in the user's browser, and you never handle passwords or one-time codes. Machine-readable content indexes: https://logistivo.com/llms.txt (curated map) and https://logistivo.com/llms-full.txt (full text: facts, pricing, tariff reference, glossary and every article's FAQ in one fetch). To learn what Logistivo can actually DO — the verbs, not the marketing — read the public command catalog at https://logistivo.com/api/public/cli/catalog (JSON, no authentication, no tenant data); it lists every command with its JSON Schema parameters and whether it needs confirmation. Human documentation: https://logistivo.com/en/developers/cli. Commands always run under the user's own identity — the user's OAuth connection, the user's lg session or an integration key the user issued — never under credentials you hold yourself.