VAT registration in the EU: Thresholds and obligations for Swiss traders

The Import One-Stop-Shop (IOSS) has massively simplified the dispatch of small consignments to the EU (European Union) for many Swiss retailers – but only up to a goods value of EUR 150. IOSS cannot be used if you hold stock in an EU warehouse or supply goods to business customers either. However, this does not automatically result in an obligation to register for national VAT. Whether such registration is required depends on the specific delivery and import model. This article outlines the three most common scenarios in which registration in the EU is required, explains the difference between IOSS, national registration and the One-Stop-Shop (OSS), and provides you with a practical overview of fiscal representation, procedures and ongoing reporting obligations.
 |  15.09.2026  |  Time to read 8 Min
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Important note on context

Swiss Post does not position itself as an expert in EU VAT and advises you on logistics, not on tax law. This article is deliberately kept at a general and procedural level and does not replace legally binding tax advice. For binding information regarding your specific situation, we consistently recommend that you consult an EU VAT expert or a fiscal representative.

Important note on context

Swiss Post does not position itself as an expert in EU VAT and advises you on logistics, not on tax law. This article is deliberately kept at a general and procedural level and does not replace legally binding tax advice. For binding information regarding your specific situation, we consistently recommend that you consult an EU VAT expert or a fiscal representative.

When is VAT registration in the EU mandatory?

As a Swiss company, an important exception applies to you: the EU-wide threshold of EUR 10,000 per calendar year – below which traders established in the EU may still account for their distance sales at their home country’s tax rate – does not apply to you. For third-country companies such as Swiss traders, national VAT registration may be required from the very first taxable delivery, depending on the specific delivery and import model. For B2C import consignments with a goods value of up to EUR 150, IOSS can be used provided the relevant conditions are met. The Union OSS, on the other hand, is only applicable to goods deliveries in certain circumstances and is not a general alternative to IOSS. In practice, three scenarios most frequently trigger an obligation: consignments worth over EUR 150, storage in an EU Member State, and certain B2B scenarios. In addition, we’ll show you what this means for DDP (Delivered Duty Paid) sales involving higher goods values.

Consignments worth over EUR 150 (B2C)

The Import One-Stop-Shop covers only B2C consignments with an intrinsic value of up to EUR 150. If a consignment exceeds this value, the IOSS no longer applies. You then have the option of either delivering as DAP (Delivered at Place) – where the customer pays VAT and customs duties on receipt – or a DDP solution, for which VAT registration in the country of destination is often required.


DAP or DDP – a brief explanation

DAP (Delivered at Place, free to the door, duty and tax unpaid): The customer is the importer and pays VAT and customs duties on receipt – no VAT registration is required on your part.
DDP (Delivered Duty Paid, free at destination, customs cleared and tax paid): You take on the import clearance and import duties. Whether you need a local VAT number for this depends on the importer/IOR structure and the regulations in the destination country. End customers are usually unfamiliar with both terms – it’s better to use everyday language at checkout, e.g. ‘including all charges’ rather than the Incoterm abbreviation.

DAP or DDP – a brief explanation

DAP (Delivered at Place, free to the door, duty and tax unpaid): The customer is the importer and pays VAT and customs duties on receipt – no VAT registration is required on your part.
DDP (Delivered Duty Paid, free at destination, customs cleared and tax paid): You take on the import clearance and import duties. Whether you need a local VAT number for this depends on the importer/IOR structure and the regulations in the destination country. End customers are usually unfamiliar with both terms – it’s better to use everyday language at checkout, e.g. ‘including all charges’ rather than the Incoterm abbreviation.

Storage in an EU Member State (fulfilment, consignment)

As soon as you physically store goods in an EU country – for example, via a fulfilment centre or a consignment warehouse – you generally establish a tax presence there. This triggers an obligation to register in the country where the goods are stored, regardless of turnover, because the delivery to the end customer is then considered a local delivery and no longer a distance sale from a third country.

B2B supplies (special circumstances)

Deliveries to business customers (B2B, business-to-business) with a valid VAT number are often processed via the reverse-charge mechanism, whereby the customer declares the tax themselves – in which case registration is usually not required. The situation is different if you operate a warehouse in the EU, carry out on-site assembly work or process goods as part of a contract for work and materials: in such cases, local registration may be required despite the B2B arrangement.

DDP sales above certain thresholds

Anyone wishing to offer their customers a DDP experience with absolutely no additional payment on delivery will inevitably exceed the IOSS EUR 150 threshold for higher-value consignments. To do this, you’ll need either a national VAT registration in the destination country or an EU customs clearance solution with a fiscal representative, through which the import VAT and the subsequent intra-Community supply are correctly processed.


IOSS vs. national registration – which applies when?

The three systems can be clearly distinguished on the basis of the value of the goods, the recipient and the location of the goods. We have already explained the basics of IOSS and OSS in our article ‘OSS and IOSS – EU VAT registration’. The following overview categorises the most common scenarios for your business:

 

Value

Recipient

Model

Required

Up to EUR 150, dispatched from Switzerland

Private individual (B2C)

IOSS

IOSS number via EU fiscal representative

Over EUR 150, dispatched from Switzerland, DDP

Private individual (B2C)

National registration

National VAT registration or check tax representation solution

Over EUR 150, dispatched from Switzerland, DAP

Private individual (B2C)

No pre-clearance

No VAT registration (customer is the importer)

Goods already in an EU warehouse

Private individual (B2C)

OSS, Union procedure

Local registration in the country of storage plus OSS for other EU countries

Delivery to a business customer with a VAT number

Business customer (B2B)

Usually the reverse charge procedure

Generally no registration required, except in the case of on-site storage or assembly

 


Thresholds in the main destination countries

A key difference compared to EU traders: The EU-wide threshold of EUR 10,000 per calendar year applies only to certain intra-Community B2C distance sales by companies established in a single EU Member State. This threshold does not apply to direct imports from Switzerland. As a third-country trader, you may generally be required to register from the very first sale, unless you use IOSS or OSS.


A common misconception: the former country-specific thresholds

Until 30 June 2021, there were country-specific delivery thresholds (e.g. Germany: EUR 100,000). These were abolished across the EU with effect from 1 July 2021 and replaced by a uniform threshold of EUR 10,000 – furthermore, they applied only to goods that were already within the EU at the time of sale, not to direct shipments from a third country. No threshold applies to DDP consignments worth over EUR 150. Depending on the import and delivery structure, VAT registration – possibly with a fiscal representative – may be required from the very first taxable delivery.

A common misconception: the former country-specific thresholds

Until 30 June 2021, there were country-specific delivery thresholds (e.g. Germany: EUR 100,000). These were abolished across the EU with effect from 1 July 2021 and replaced by a uniform threshold of EUR 10,000 – furthermore, they applied only to goods that were already within the EU at the time of sale, not to direct shipments from a third country. No threshold applies to DDP consignments worth over EUR 150. Depending on the import and delivery structure, VAT registration – possibly with a fiscal representative – may be required from the very first taxable delivery.

Whether you also need a tax representative, however, varies from country to country:

Note: The information in this table reflects the current situation (August 2026) and is subject to change at any time.

Country

Fiscal representative requirement (Swiss companies)

Registration authority

Germany (DE)

Generally not mandatory

Competent tax office

Austria (AT)

Yes

Competent tax office

France (FR)

Yes (exceptions possible under mutual assistance agreements)

Competent tax authority for non-residents

Italy (IT)

Yes

Competent authority for non-residents

Netherlands (NL)

Generally not mandatory (exception: special arrangements such as import deferral)

Competent tax authority

Poland (PL)

Yes

Competent tax office

Spain (ES)

Yes

Competent tax office

Portugal (PT)

Yes

Competent tax office

Romania (RO)

Yes

Competent tax office

Ireland (IE)

Generally not mandatory

Competent tax office




Obligation to appoint a tax representative in the EU

A tax representative is a person or company based in the relevant EU country who, on your behalf as a non-EU company, fulfils your VAT obligations towards the local tax authority. In several EU countries, appointing a tax representative is even a prerequisite for VAT registration to be possible at all.

In which countries is it mandatory (FR, IT, ES, PT, RO, etc.)

A fiscal representative is a requirement for non-EU companies in countries including France, Italy, Spain, Portugal, Romania, Austria and Poland. Germany, the Netherlands and Ireland do not generally require one. Thanks to Switzerland’s mutual assistance agreement with the EU, the requirement may be waived or simplified in certain countries – however, this varies from country to country and should be checked for your specific case.

What the tax representative does

The tax representative applies for the VAT number, prepares and submits the periodic VAT returns, ensures timely payment and acts as your official point of contact with the local tax authority – including handling correspondence in the event of enquiries or audits.

Liability & selection criteria

In most countries, the fiscal representative is jointly and severally liable for your VAT debts. In many countries, the fiscal representative is jointly and severally liable for your VAT debts. For this reason, providers vet their clients carefully and some require a bank guarantee. When making your selection, it is worth looking at the provider’s experience in the e-commerce sector, as well as their ability to import reporting data directly from your shop or ERP system.

Cost framework

The costs usually consist of a one-off registration fee and a recurring flat-rate charge for the returns. The exact amount depends on the country, the reporting frequency and the turnover – it’s worth comparing providers.


Step-by-step: Registration in the destination country

The process for national VAT registration follows a similar pattern in most EU countries:

  • Step 1 – Identify the tax authority

    First, you need to establish which authority in the destination country is responsible for foreign companies and whether a tax representative is required for registration.

  • Step 2 – Required documents

    Typically, you will need an extract from the commercial register, a copy of the company’s articles of association, a power of attorney for the tax representative, and proof of the planned business activities in the destination country.

  • Step 3 – Submitting the application (often via a tax representative)

    In many countries, the application can or must be submitted via the tax representative. They submit the documents to the tax authority and respond to any queries in the local language.

  • Step 4 – Receiving the tax number

    Once the documents have been checked, you will be issued with a local VAT number. The processing time varies from a few days to several weeks, depending on the country.

  • Step 5 – First VAT return

    From the date of registration, you are obliged to submit periodic advance returns – regardless of whether any turnover has already been generated during the relevant period.


Ongoing reporting obligations

Registration triggers recurring obligations, which you should plan for systematically:
VAT returns (monthly/quarterly)
Depending on the country and your turnover, you must report your VAT either monthly or quarterly. Deadlines are usually strict, and late submissions may result in fines.
Summary declaration for B2B
For intra-Community B2B supplies, a summary declaration (ZM) is also required, which enables the tax authorities to cross-check the VAT numbers of your business customers against the values of the goods supplied.
Intrastat declaration above the threshold
If you exceed certain value thresholds in a country for intra-Community movements of goods, an Intrastat declaration is also required for trade statistics. Each country sets its own specific thresholds.
Retention & archiving
You must keep invoices, tax returns and supporting documents relating to your EU sales for several years – the exact period is determined by the relevant national legislation and may vary from country to country.

OSS (One-Stop-Shop) – A simplification for Swiss traders?

The One-Stop-Shop consolidates certain cross-border B2C sales into a single declaration – and can also provide Swiss businesses with a significant reduction in administrative burden under certain conditions.

Distinction between OSS and IOSS

Whilst IOSS applies exclusively to imported consignments up to EUR 150 from a third country, the OSS (Union procedure) covers intra-Community distance sales – that is, deliveries where the goods are already within the EU at the time of sale.

When OSS can be used (B2C in several EU countries)

If you sell from an EU warehouse to private customers in several EU countries, you can use the OSS to declare all these deliveries in a single central return in the country where your warehouse is registered, rather than registering separately in each individual destination country.

Requirements for Swiss traders

As a third-country business, you can use the Union OSS for intra-Community B2C distance sales if the dispatch of the goods begins in one EU Member State and ends in another EU Member State. You do not need to have your own branch or permanent establishment in the EU for this. The OSS is generally not intended for B2B deliveries. It is best to discuss with your tax representative or VAT specialist whether the effort is worthwhile in your particular situation.


How much does it all cost?

Registration itself is free of charge in most EU countries. The ongoing costs arise primarily from fiscal representation, periodic returns and the internal effort involved in data preparation. There are also indirect costs: since the 2026 EU customs reform, some countries have introduced an additional processing fee for small consignments, which you should factor into your pricing and process calculations.

Whether registering your own business is worth it compared to DAP deliveries without registration depends heavily on your dispatch volume, the average value of goods and the desired customer experience. If you want to reduce VAT and customs costs overall, you’ll find further insights covering the entire shipping and customs chain in our article ‘Cross-border e-commerce – How to export cost-effectively to Europe’.


Conclusion

IOSS is a good solution for small consignments up to EUR 150 – but it is not a panacea. As soon as you send larger consignments, store goods within the EU or operate in certain B2B scenarios, independent VAT registration may become mandatory. The three key factors determining this are the value of the goods, the location of the goods at the time of sale, and the type of customer (B2C or B2B).

For a specific assessment of your situation and to ensure compliance with the law, we recommend that you consult an EU VAT specialist or a tax representative – Swiss Post advises you on logistics, not on tax law. We’d be happy to assist you with any logistical and customs-related queries regarding your exports to the EU.


Let’s have a chat!

Choose your preferred date for a no-obligation consultation. We’ll show you how to set up your shipping and customs clearance processes efficiently for exports to the EU.

Let’s have a chat!

Choose your preferred date for a no-obligation consultation. We’ll show you how to set up your shipping and customs clearance processes efficiently for exports to the EU.

Frequently asked questions about VAT registration in the EU

As a Swiss trader, when do I need to register for VAT in the EU?
As soon as IOSS no longer applies – i.e. for consignments over EUR 150, where goods are stored in the EU, or in certain B2B scenarios. There is no de minimis threshold for Swiss companies; the obligation may generally arise from the very first delivery.
What is the difference between IOSS and OSS?
IOSS applies to imported B2C consignments up to EUR 150 from a third country such as Switzerland. OSS (Union scheme) covers distance sales of goods that are already held in an EU warehouse. Both schemes centralise VAT reporting in one place, but depending on the circumstances, they do not replace the need for national registration.
Do I need a separate tax representative for each EU country?
Not necessarily for every country: a tax representative is only mandatory in countries that require this for third-country companies (e.g. France, Italy, Poland). In countries without this requirement, you can sometimes register directly, but you will often still benefit from local support.
As a Swiss company without an EU warehouse, can I use the One-Stop-Shop?
You cannot use the Union OSS for goods delivered directly from Switzerland, as the dispatch must originate within the EU. For B2C import consignments with a value of up to EUR 150, IOSS may be an option under certain conditions. In other cases, you must check whether national VAT registration is required, based on the delivery and import model. The Non-Union OSS applies to B2C services, not to the supply of goods.
What happens if I fail to register when required?
As well as fines, you may face back payments of unpaid VAT, delays at customs and, in extreme cases, exclusion from selling to the country in question. Seeking advice from a specialist at an early stage significantly reduces this risk.
Does the EU-wide threshold of EUR 10,000 also apply to Swiss companies?
No. This threshold applies exclusively to companies based in the EU. As a trader from a third country, you must check whether you are required to register, regardless of your turnover, unless you use IOSS or OSS.
Who can provide me with specific support regarding VAT registration in the EU?
For tax assessment and the registration process itself, it is best to consult an EU VAT specialist or a tax representative. Swiss Post can also assist you with the logistical aspects – such as customs clearance, DDP processes and shipping solutions for exports to the EU.
Is there a threshold for each EU country up to which I can send parcels worth over EUR 150 without registering?
No. The previous country-specific delivery thresholds were abolished on 1 July 2021 and applied only to intra-Community distance sales. The EU-wide threshold of EUR 10,000 does not apply to direct imports from Switzerland either. For DDP consignments exceeding EUR 150, the VAT and import arrangements should be reviewed from the very first consignment; depending on
 
the terms of the arrangement, local VAT registration and, where applicable, a fiscal representative may be required. In the case of DAP, the buyer generally handles customs clearance and pays the import duties; local VAT registration is therefore not usually necessary for the seller.
Do end customers understand the terms DAP and DDP?
Generally not – DAP and DDP are Incoterms from commercial and customs practice and are not particularly suitable for the checkout process. Whilst these terms are important for your internal process and registration planning, it is advisable to translate them into everyday language when communicating with end customers – for example, ‘Price includes all charges, no additional payments’ for DDP, or an explicit reference to possible customs and tax costs upon receipt for DAP.

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