MARKET ACCESS / OSS VAT
How does a brand handle VAT across the 27 EU member states?
Under the EU One-Stop-Shop scheme, a single OSS registration covers VAT obligations on cross-border sales across the 27 EU member states. EFC handles this as OSS VAT run inside its operation. A non-EU brand then meets its VAT obligations across the single market through one registration as orders ship.
THE MECHANISM
One registration,
the 27 member states,
inside one operation.
The One-Stop-Shop scheme replaces separate VAT registrations in each member state with a single registration that covers cross-border sales across the 27. A brand may sell D2C orders from its own store into multiple countries. For that brand, OSS keeps the VAT obligations manageable as volume spreads across the single market.
EFC runs OSS VAT as part of the operation that imports, holds, and ships the stock. VAT is accounted for as orders ship, rather than handled as a separate exercise.
OSS works alongside fiscal representation and customs clearance. Goods are usually released for free circulation on arrival, or held under bond with duty and import VAT suspended where the goods suit it.
THE REACH
One registration reaches every member state behind the same wall.
The 27 member states sit behind one boundary. OSS is the single registration that covers the VAT on cross-border sales across all of it. Most of the country-by-country VAT registration work falls away.
Going deeper
Union, non-Union or import OSS: which scheme applies?
The One-Stop-Shop comes in three schemes, and only one of them fits stock that already sits inside the EU. A seller from outside the EU that ships to consumers in other member states from EU stock uses the Union scheme.
| Scheme | What it covers | Who uses it | Return |
|---|---|---|---|
| Union scheme | Distance sales of goods to consumers from one member state to another, plus certain services | EU sellers, and sellers from outside the EU shipping from stock held in the EU | Quarterly (Article 369f) |
| Non-Union scheme | Services supplied to consumers in the EU by businesses not established there | Service providers from outside the EU. It does not cover goods | Quarterly (Article 364) |
| Import scheme (IOSS) | Distance sales of goods sent from outside the EU in consignments worth EUR 150 or less, excise goods excluded | Sellers shipping parcels from outside the EU. A seller from outside the EU generally needs an intermediary established in the EU | Monthly (Article 369s) |
What does OSS not cover?
OSS covers VAT on business-to-consumer sales that cross from one member state into another, and nothing wider. Import VAT, domestic sales, sales to businesses and several other items stay outside it.
| Item | Covered by OSS? | Where it is dealt with instead |
|---|---|---|
| Import VAT when goods enter the EU | No | At import. Where the importer qualifies, it is accounted for in the ordinary VAT return |
| A sale to a consumer in the country the goods ship from | No | It is a domestic sale, taxed and reported under that country's rules |
| A sale to a VAT-registered business in another member state | No | Zero rated as an intra-Community supply when the conditions are met (VAT Directive, Article 138), and listed in the recapitulative statement |
| A marketplace sale of EU-held goods by a seller from outside the EU | Not in the seller's return | The marketplace is treated as the supplier to the consumer (Article 14a(2)), and the seller's supply to the marketplace is exempt (Article 136a) |
| Moving your own stock to a warehouse in another member state | No | It is treated as an intra-Community supply (Article 17) and needs VAT registration there |
| Deducting input VAT | No | Input VAT cannot be deducted in the OSS return (Article 369j) |
How does the quarterly OSS return work?
The Union scheme runs on one electronic return per calendar quarter, filed with a single member state. For a seller from outside the EU, that is the member state where the goods start their journey (Article 369a). It is Portugal when stock ships from Portugal.
- Record each sale by country. Every cross-border consumer sale is recorded against the member state where the goods arrive, at that country's VAT rate.
- File once a quarter. One return goes to the member state of identification for each calendar quarter, whether or not any sales took place (Article 369f).
- Meet the deadline. The return is due by the end of the month after the quarter ends (Article 369f). For July to September, that is 31 October.
- Pay in one payment. The total VAT is paid to the member state of identification, referencing that return, by the same deadline (Article 369i). That member state passes each share on to the country of consumption.
- Keep the records. Records of each sale must be kept for ten years (Article 369k). A mistake is corrected in a later return, within three years of the original due date (Implementing Regulation (EU) No 282/2011, Article 61).
THE BOUNDARY
Precise about the function.
What it is
- OSS VAT accounted for within the operation, so a non-EU brand meets its cross-border VAT obligations across the 27 member states under one registration.
What it is not
- Not bespoke tax advice or tax planning.
- Not a substitute for local VAT registration where one is still required. Examples are a domestic sale inside the member state where the stock is held, or a sale to a business.
- Not MDR, CE, or device certification.
- The GPSR Responsible Person credential is a separate, consumer-products-only role.
IN ONE SENTENCE
One One-Stop-Shop registration covers VAT obligations across the 27 EU member states,
and EFC runs OSS VAT as part of the operation as orders ship.
Under the EU One-Stop-Shop scheme,
the VAT Directive, Directive 2006/112/EC.
Questions
Frequently asked questions
How does the OSS single registration sit alongside customs clearance and fiscal representation?
OSS is the single registration that covers VAT obligations on cross-border sales across the 27 member states. Alongside it, goods are released for free circulation on arrival or, where they suit it, held under bond with duty and import VAT suspended. Fiscal representation gives the brand the VAT standing it needs inside a member state. The import side and the VAT side are handled inside the same base.
How does OSS VAT relate to selling D2C and marketplace orders?
OSS covers distance sales of goods to consumers in other member states, such as a brand's own D2C orders into several EU countries. When a seller established outside the EU sells on a marketplace, the marketplace facilitating the sale is the deemed supplier. The marketplace holds that status under Article 14a(2) of the VAT Directive and accounts for the consumer VAT. One pool of stock serves a consumer parcel, a marketplace order, and a wholesale pallet.
Is OSS the same as IOSS?
No. OSS (the One-Stop-Shop) covers VAT on cross-border B2C sales of goods already in free circulation inside the EU. That is how orders ship once stock has been released, usually on arrival. IOSS (the Import One-Stop-Shop) is a separate scheme for low-value consignments imported directly to the consumer from outside the EU. Because the EFC model lands stock inside the single market first and then ships from there, OSS is the scheme that applies to those sales.
Does the EUR 10,000 threshold apply to a seller from outside the EU?
No. The EUR 10,000 threshold in Article 59c of the VAT Directive applies only to sellers established in a single member state. A seller established outside the EU owes VAT in the customer's member state from the first cross-border sale to a consumer. The Union OSS scheme is how that VAT is reported through one return.
One VAT registration across the single market.
See how fiscal representation gives your brand its standing, or how the bonded route works.
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