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The OSS will be broadened to include additional types of transactions, such as domestic B2C supplies by non‑established businesses, installation and assembly supplies, supplies made on board ships, aircraft and trains, and supplies of gas, electricity, heating and cooling. In addition, movements of a business’s own goods between EU Member States will be brought within the scope of the OSS.
By expanding the OSS scheme and extending the reverse‑charge mechanism to more transactions carried out by non‑established suppliers, businesses will in more cases be able to operate within the EU using a single VAT registration, rather than having to register for VAT in multiple Member States.
The EU’s VAT in the Digital Age (ViDA) package was adopted on 11 March 2025. For more information, we refer to our articles What ViDA means for your business? and Update on the EU’s VAT proposal for Digital Age (ViDA).
The ViDA rules represent an important step towards a more uniform and efficient VAT system within the EU. The package can be divided into three main areas:
The current Dutch proposal focuses on implementing the first area: the measures aimed at achieving a single VAT registration. The objective of these measures is to limit situations in which non‑established businesses are required to register for VAT in several Member States. A wider range of transactions will be reportable through the OSS, including transfers of a business’s own stock. In addition, the reverse‑charge mechanism will be extended to cover more transactions.
The single VAT registration measures consist of an expansion of the scope of the OSS and an extension of the reverse‑charge mechanism. The changes will enter into force in stages, namely in January 2027, July 2028 and July 2029.
The proposed measures can be divided into three main areas:
The OSS scheme currently allows e‑commerce businesses and marketplaces that sell goods B2C in other Member States to fulfil their VAT compliance obligations via a single online portal. In addition, several cross‑border B2C services supplied within the EU can already be reported through the OSS. Businesses that opt for the OSS are not required to register for VAT purposes in other Member States, nor to declare and remit VAT there.
The OSS will be expanded in stages. The first step concerns supplies of gas, electricity, heating and cooling as from 1 July 2027. This will be followed by an expansion to B2C supplies made by businesses that are not established in the EU Member State of consumption as from 1 July 2028.
The OSS will be extended to cover B2C supplies of gas, electricity, heating and cooling.
As from 1 July 2028, the scope of the OSS will be further expanded to include all B2C services supplied in Member States where the supplier is not established.
In addition, the Union OSS scheme will be extended to cover domestic B2C supplies of goods made by businesses that are not established for VAT purposes in the Member State of consumption. The OSS will also be extended to cover specific supplies of goods, such as installation and assembly supplies, as well as supplies made on board ships, aircraft or trains.
The OSS will also apply to certain business‑to‑business (B2B) supplies facilitated by electronic interfaces, where a platform enables a non‑EU seller to supply goods to taxable persons established in the EU.
Businesses often need to transfer goods from one EU Member State to another in order to use those goods for business purposes in the Member State of destination. For example, an e‑commerce business may transfer stock to another Member State to fulfil orders from a warehouse located there. In other cases, a business may need to transfer capital goods, such as machinery, to another Member State.
Under the current rules, a business that transfers goods from the Netherlands to another EU Member State without selling them is generally required to register for VAT in the Member State of destination. The transfer must be reported both in the Member State of departure and in the Member State of arrival, for example through VAT returns, EU Sales Listings (ESL) and, in some cases, Intrastat reports.
As from 1 July 2028, such transfers may be reported through a Union OSS return. A business that opts for the OSS will no longer be required to register for VAT in other Member States for its transfers of own goods. Instead, these transfers can be declared through the OSS.
For transfers reported through the OSS, the corresponding intra‑Community acquisition in the Member State of destination will be exempt from VAT. As a result, businesses will no longer need to register for VAT purposes in the Member State of destination or report the arrival of goods there.
If a business opts to use the OSS to report movements of its own stock to another Member State and subsequently supplies goods to a non‑VAT‑registered customer in that Member State, those supplies must also be declared through the OSS.
If, after a transfer, a business decides to use the goods for purposes other than taxable business activities, for example for private use or VAT‑exempt activities, the VAT due can be declared and paid through the OSS. This avoids additional administrative obligations in the Member State of destination.
Call‑off stock arrangements that currently fall under the EU simplification regime will also be reportable through the Union OSS.
As from 1 July 2028, no new transfers of stock under the EU call‑off stock arrangements may be made. For call‑off stock arrangements that started on or before 30 June 2028, the existing conditions, including the 12‑month time limit for transferring ownership of the goods to the intended purchaser, will continue to apply.
The call‑off stock simplification will cease to apply entirely as from 30 June 2029. At that point, the simplification will no longer be required, as movements of own goods can be reported through the Union OSS.
Using the OSS instead of maintaining local VAT registrations in multiple Member States is not mandatory. Businesses will therefore need to assess which option is most beneficial for their specific situation. However, if a business opts for the OSS, it is required to report all transactions that fall within the scope of the OSS through this scheme.
It is important to note that not all supplies can be reported via the OSS. For example, most B2B supplies fall outside its scope. In addition, input VAT cannot be deducted through the OSS. As a result, a business may still need to maintain VAT registrations in Member States where it carries out transactions that cannot be reported via the OSS.
In some cases, a business may also decide not to opt for the OSS if it prefers to deduct input VAT through local VAT returns in several Member States, rather than reporting transactions through the OSS and reclaiming input VAT via a refund procedure for non‑VAT‑registered businesses.
As from 1 July 2028, the domestic reverse‑charge mechanism will apply to all B2B supplies of goods and services made by non‑established and non‑VAT‑registered businesses, provided that the recipient is registered for VAT in the Netherlands. Under this mechanism, the obligation to account for VAT shifts from the supplier to the customer. As a result, overseas suppliers will no longer need to register for VAT in the Netherlands if their Dutch customer is VAT registered.
Non‑Dutch suppliers will be required to report transactions subject to this extended reverse charge in the EU Sales Listing as from 1 July 2028, and in the EU Digital Reporting Requirements (e‑invoicing and digital transaction‑based reporting) as from 1 July 2030. Dutch VAT‑registered purchasers must also report reverse‑charged purchases in their VAT return as from 1 July 2028 and in the EU digital reporting system as from 1 July 2030, unless the Netherlands opts out of this obligation.
Because the new reverse charge will be subject to reporting in the EU Sales Listing as from 1 July 2028 and to digital reporting under ViDA as from 1 July 2030, it is expected that a separate reporting box will be introduced in the Dutch VAT return and in the EU Sales Listing for supplies subject to this reverse charge.
To prevent inconsistencies between reporting by suppliers and purchasers in different Member States, further clarification is expected from the legislator on which reverse‑charge rule takes precedence if multiple reverse‑charge mechanisms apply to the same transaction. For example, if a non‑established and non‑VAT‑registered supplier supplies integrated circuits to a Dutch‑established and VAT‑registered customer, the transaction could fall under three reverse‑charge regimes in the Netherlands. It should be further clarified in final legislation that EU Sales Listing, e-invoicing and digital reporting obligation applies to all B2B supplies of goods and services made by non‑established and non‑VAT‑registered businesses, provided that the recipient is registered for VAT in the Netherlands.
The proposed changes, including the expanded scope of the OSS, the introduction of a special scheme for transfers of own goods and the extended application of the domestic reverse charge, are expected to reduce VAT compliance costs for businesses and are therefore generally beneficial.
The extensions are likely to be particularly advantageous for businesses operating in sectors such as e‑commerce, energy supply, including fuel cards and electric charging solutions, and construction.
The expansion of the reverse‑charge mechanism is also expected to have a positive impact. Businesses operating cross‑border within the EU will have fewer reasons to register for VAT in multiple Member States, as VAT will be shifted to the customer in more situations.
In some cases, it may be beneficial for non‑Dutch businesses to deregister for VAT purposes in the Netherlands if the reverse charge applies to all of their supplies, unless they incur deductible input VAT in the Netherlands that is more efficiently recovered through a Dutch VAT return.
We can support your organisation in understanding how ViDA affects your business and in preparing for the upcoming changes.
An introductory session explaining the main ViDA changes that are relevant to your business. This workshop familiarises your organisation with upcoming VAT changes and their high‑level impact.
An analysis of the impact of ViDA on your business. This includes assessing whether your organisation will be subject to e‑invoicing or digital reporting obligations in any EU Member State. We also assess whether you may be able to deregister for VAT in certain Member States as a result of expanded OSS reporting or the application of the reverse charge.
This work includes mapping your transactions, assessing your systems and software, and evaluating the overall impact of ViDA on your VAT position.
Identification of the steps required to comply with the ViDA requirements and the associated timeline. We develop a clear and practical roadmap to prepare your people and systems.
Practical support with implementing the required changes to prepare your organisation for the ViDA requirements.
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