The EU e-commerce VAT package introduced the requirement for non-EU sellers or marketplaces using the new import scheme – IOSS Import One-Stop Shop – to appoint an EU resident Intermediary. IOSS is the new return introduced from 1 July 2021 for reporting the import distance selling of goods consignments not exceeding €150 to EU consumers.
Update: the EU is proposing the €150 threshold for use of IOSS be withdrawn from 1 March 2028.
Non-EU Sellers and marketplaces will need to disclose their appointed Intermediary’s IOSS identification number (see below) on their consignments being imported into the EU on their way to their EU customers. Failure to do so will result in the goods potentially being blocked at EU customs.
NOTE: non-EU sellers do not require an Intermediary for the other new return, One-Stop Shop OSS return, for reporting distance sales within the EU. Preparing OSS or IOSS returns can be challenging. VAT Calc’s single platform VAT Filer can accurately complete either filings with verified transactional data from our VAT Calculator or VAT Auditor integrated tools.
IOSS Intermediary responsibilities
An Intermediary is a type of VAT or Fiscal representative, which the tax authorities can communicate with on returns and audits. The Intermediary is responsible for all the VAT obligations of the seller or marketplace, including the filing of IOSS returns and payment for any VAT.
In some EU countries, an Intermediary may be jointly and severally liable for their clients’ import VAT. This will likely mean the Intermediary will request extra fees and / or a financial security, e.g. bank guarantee.
Registering as an Intermediary
Prior to being appointed as an Intermediary, the agent/person must first register in their member state of residence as and Intermediary. They will be granted their own unique IOSS Intermediary identification number.
The Intermediary must then register in their state of identification each client they will represent for IOSS purposes.
Do UK sellers using IOSS need an IOSS Intermediary?
No. Following the end of the UK’s Brexit transition period on 31 December 2020, the UK is a full third-country for EU purposes. As part of the EU-UK Trade and Cooperation Agreement, a Mutual Assistance clause on VAT means that EU countries should not apply the Intermediary or Fiscal Representative requirement on UK businesses for IOSS. However, some countries are still waiting clarification on this, and sellers should check in advance with VAT agents.
Norway is the other non-EU country to have also signed a mutual Assistance agreement with the EU.