VATCompass Analysis Report | ID: ANL-0000201 | Confidential
VAT Compliance Analysis Report
VATCompass · Country-by-country VAT obligation screening
VAT STATUS
Based on the information you provided, you likely need VAT registrations in each EU country where you store inventory. At the moment, registrations appear to be missing in Germany (DE), and those should be started as soon as possible.
Because your business is established outside the EU, the usual €10,000 EU distance-sales threshold does not apply to you. That means VAT on qualifying B2C sales to EU customers is generally due in the customer's country from the first sale.
You may also be able to use the Union OSS scheme for those cross-border B2C sales, but only if you are eligible and properly registered. If you use OSS, you must choose one EU country as your registration point from the countries where your goods are dispatched (Germany (DE), the Netherlands (NL) or Poland (PL)). Confirm eligibility and register before relying on OSS.
Scheme: Local VAT registration · Report ID: ANL-0000201 · Generated: 23 July 2026
At a Glance
Urgent Action
Missing VAT registration in Germany (DE) (stock held there without one).
Start the registration in Germany (DE) this week.
Next Step
B2C intra-EU distance sales with no threshold available and no OSS in place.
Register for Union OSS if eligible, using a stock country as Member State of identification.
B2B reverse charge should be supported by valid VAT number checks.
Validate every business customer in VIES and keep the evidence.
Already In Place
Existing registrations in the Netherlands (NL), Poland (PL).
Keep filings current.
Why this matters
When stock is held in a country, VAT obligations usually start as soon as the goods arrive, not only after a sales threshold is reached. If the business trades without the required registration, unpaid VAT, interest, and penalties can build up over time, often without being immediately visible. Putting the missing registration in place and setting up OSS where applicable turns a growing exposure into a clear and manageable filing process.
Executive Summary
Your business, established in US with a reported annual turnover of €250,000, stores goods in Germany (DE), the Netherlands (NL), and Poland (PL). Holding inventory in a country generally creates a VAT registration obligation there — this is the dominant finding of this screening and takes priority over the other considerations.
Based on the registrations you reported, registrations appear to be missing in Germany (DE). Until these are in place, supplies made from that stock may be occurring without the required VAT registration, which creates growing exposure to back taxes, interest, and penalties. Registering as soon as possible is the way to become compliant.
In addition, the €10,000 EU distance-sales threshold applies only to businesses established in a single EU Member State and does not apply to your business, so VAT on qualifying B2C intra-EU distance sales of goods is generally due in each customer's Member State from the first sale. The Union OSS scheme may be a suitable reporting option if you are registered and eligible — you must select a Member State of identification from which your goods are dispatched (Germany (DE), the Netherlands (NL) or Poland (PL)). Confirm eligibility and register before relying on OSS.
1. Client Profile
| Company | DEMO sample goods EU |
| Country of Establishment | US |
| Business Type | Physical goods |
| Customer Type | Both |
| Goods / Services | Goods |
| Annual Turnover | €250,000 |
| Digital Services | No |
| EU Inventory | Yes |
| Sales Countries | AT, BE, CZ, DE, NL, PL |
| Stock Countries | DE, NL, PL |
2. VAT Triggers Analysis
| Trigger | Status & Finding |
|---|
| Trigger 1 — EU Inventory Storage (Primary) |
You hold stock in Germany (DE), the Netherlands (NL), Poland (PL). Physical storage of goods generally creates a taxable presence in each of those countries, and this is typically a strong registration trigger independent of sales volume. Each stock country generally requires its own local VAT registration, local-rate VAT on supplies made from that stock, and periodic local VAT returns.
Based on the registrations you reported, registrations appear to be missing in: Germany (DE). Where an obligation exists, it generally starts when stock first arrives, so registering as soon as possible is the way to become compliant.
|
| Trigger 2 — B2B Sales: Reverse Charge |
Where your customer is a genuine taxable person with a valid VAT number and the supply qualifies, cross-border B2B sales are taxed in the customer's country under the reverse charge, with the customer self-accounting for VAT. Obtain each customer's VAT number and validate it through VIES before invoicing without VAT — keep the validation evidence. A sale to a customer without a valid VAT number must generally be treated as B2C.
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| Trigger 3 — B2C Distance Sales: No Threshold Available, No OSS Indicated |
The €10,000 EU annual threshold is only available to certain EU-established businesses and does not apply to you. VAT on qualifying B2C intra-EU distance sales of goods is generally due in the customer's country from the first sale. The Union OSS scheme may be used if you are registered and eligible — as a non-EU business, choose a Member State of identification where your goods are dispatched from (DE, NL or PL). A Union OSS registration is in addition to your local VAT registrations for stock.
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| Trigger 4 — Import of Goods into the EU |
Importing goods into the EU may trigger import VAT. Where goods are moved into EU stock for onward sale, that is usually a separate customs/VAT flow from IOSS. IOSS remains available only for qualifying direct-to-consumer consignments of up to €150. A separate new €3-per-item customs duty may also apply to eligible low-value consignments — confirm the treatment with your carrier or customs broker.
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KEY FINDING
Based on the information you provided, you likely need VAT registrations in each EU country where you store inventory. Registrations appear to be missing in Germany (DE) and should be started as soon as possible. Because the business is established outside the EU, the €10,000 distance-sales threshold does not apply — VAT on qualifying B2C sales is generally due in the customer's country from the first sale, with Union OSS as a possible reporting option once registered and eligible.
3. Applicable VAT Scheme
Local VAT registration
You hold inventory in EU warehouses (Germany (DE), the Netherlands (NL), Poland (PL)). Storing goods in a country generally creates a taxable presence there, so a local VAT registration is typically indicated in each storage country: charging that country's VAT rate on supplies made from that stock, and filing periodic local VAT returns. Generally, domestic supplies made from local stock are reported through the local registration rather than OSS.
Separately, the €10,000 EU threshold does not apply to businesses established outside the EU. VAT on qualifying B2C intra-EU distance sales of goods is therefore generally due in each customer's Member State from the first sale. The Union OSS scheme may be used to report these sales if you are registered and eligible — choose a Member State of identification where your goods are dispatched from (DE, NL or PL). OSS runs alongside your local VAT registrations.
4. Required VAT Registrations
| Country / Registration | Registration Type | Urgency |
|---|
| Germany (DE) |
Local VAT registration generally indicated — stock presence |
Immediate |
| The Netherlands (NL) |
Stock presence — existing VAT registration reported |
Verify filings up to date |
| Poland (PL) |
Stock presence — existing VAT registration reported |
Verify filings up to date |
| Union OSS Registration |
May be used for qualifying B2C intra-EU distance sales if registered and eligible. As a non-EU business, choose a Member State of identification where goods are dispatched from (DE, NL or PL). This choice generally applies for the year of registration and the following two calendar years. |
Immediate |
| Austria (AT) |
VAT due here on B2C distance sales — would be declared through the OSS registration above once in place |
Covered via OSS |
| Belgium (BE) |
VAT due here on B2C distance sales — would be declared through the OSS registration above once in place |
Covered via OSS |
| Czech Republic (CZ) |
VAT due here on B2C distance sales — would be declared through the OSS registration above once in place |
Covered via OSS |
SUMMARY: 2 registration action(s) marked Immediate. The OSS registration listed above would be ONE registration covering all listed B2C destination countries — those country lines do NOT represent separate registrations.
5. Fiscal Representative & Import VAT
Fiscal Representative (Article 204)
Fiscal representation is country-specific and is not a universal EU requirement. The flags below are indicative screening pointers based on commonly-cited practice, not a legal determination for your situation. Possibly required (check locally): Poland (PL). Often not required (check locally): Germany (DE), the Netherlands (NL). Confirm the exact requirement with a local VAT specialist in each country of registration before acting.
Import VAT Deferment
When goods are imported into the EU, import VAT becomes due at the point of entry. Depending on the country of import, you may be able to defer this import VAT and declare it in your periodic VAT return instead of paying it upfront at customs — a significant cash-flow advantage. In the Netherlands, apply for an Article 23 license once your Dutch VAT number is issued to defer import VAT at Dutch customs. This deferment mechanism is provided for under Article 211 of Council Directive 2006/112/EC.
6. Risk Assessment
| Risk Area | Level | Detail |
|---|
| Non-registration penalty |
HIGH |
Failure to register exposes the business to back taxes, interest, and penalties under each relevant Member State's VAT law. |
| Incorrect VAT rate charged |
MEDIUM |
Destination-country VAT rate must be applied to relevant sales. |
| Fiscal representative |
COUNTRY SPECIFIC |
See Section 5 — fiscal representation is country-specific; confirm the exact requirement with a local VAT specialist in each country of registration. |
| Filing & record-keeping |
MEDIUM |
Inadequate records may disallow input VAT deductions (Articles 242–248, Directive 2006/112/EC). |
7. Recommended Next Steps
IMMEDIATE (within 7 days)
— Start the VAT registration in Germany (DE) as soon as possible — stock appears to be held there without a reported registration, and registering is how you become compliant.
— The €10,000 threshold does not apply to you, so VAT on qualifying B2C intra-EU distance sales of goods is generally due in the customer's Member State from the first sale. The Union OSS scheme may be used if you are registered and eligible; choose a Member State of identification where your goods are dispatched from — DE, NL or PL. Local VAT registrations are still required for your stock.
— Ask your adviser whether the period since your first qualifying distance sale needs regularising, so it is handled in the same process as the registration.
WITHIN 30 DAYS
— Confirm with your VAT agent the exact date stock first arrived in Germany (DE) — filings may need to start from that date, and knowing it protects you from late-registration penalties.
— Once the new VAT numbers are issued, set up the first returns immediately — the filing obligation starts from the registration effective date, not from when you feel ready.
— Once any OSS registration is confirmed, update your checkout to charge each destination country's VAT rate and set up the quarterly OSS filing routine before the first return is due.
ONGOING
— If you import goods into the Netherlands, apply for an Article 23 licence with Dutch customs once your Netherlands VAT number is active — it lets you defer import VAT to your periodic return instead of paying at the border, improving cash flow.
— Ask your VAT agent whether import VAT deferment is available in Germany (DE), Poland (PL) — several countries offer equivalents to the Dutch Article 23 mechanism.
— File every OSS return on time and in full, including nil periods — repeated missed OSS returns can lead to exclusion from the scheme, which forces per-country registrations.
8. Legal Framework Referenced
This analysis is based on Council Directive 2006/112/EC (as amended), specifically Article 33 (place of supply for distance sales of goods), Article 44 and Article 196 (B2B place of supply and reverse charge), Article 59c (the €10,000 distance-sales threshold and the conditions for its availability), Article 369a (Member State of identification under the Union OSS), Title XII Chapter 6 (Union/non-Union OSS and IOSS special schemes), Article 204 (fiscal representation for non-established taxable persons), and Article 211 (import VAT deferment).
Important Notice
This analysis is based solely on the information provided in the client intake form. It does not constitute legal or tax advice and should not be relied upon as a substitute for professional advice tailored to your circumstances. No transaction-level review or source-document verification has been performed. VAT legislation and administrative practice may change at any time. Seek personalised advice from a qualified local professional before acting.
Analysis ID: ANL-0000201 · Generated: 23 July 2026 · VATCompass