VAT registration in the EU: Thresholds and obligations for Swiss traders
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
VAT returns (monthly/quarterly)
Summary declaration for B2B
Intrastat declaration above the threshold
Retention & archiving
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.
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.
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?
What is the difference between IOSS and OSS?
Do I need a separate tax representative for each EU country?
As a Swiss company without an EU warehouse, can I use the One-Stop-Shop?
What happens if I fail to register when required?
Does the EU-wide threshold of EUR 10,000 also apply to Swiss companies?
Who can provide me with specific support regarding VAT registration in the EU?
Is there a threshold for each EU country up to which I can send parcels worth over EUR 150 without registering?
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.