Importer of record requirements by country
Clearing the goods is only half the job. The other half is the VAT.
When you sell into a market where you are not established, two questions decide whether a shipment moves and what it costs. Who can act as your importer of record, and how the import VAT is structured so it is recovered rather than written off. In the European Union that usually means an indirect customs representative files for you. This hub covers both sides: the importer of record, exporter of record and representation roles on the customs side, and registration, fiscal representation, deferment and refunds on the VAT side. Expand any country below to see how the rules apply.
Can a non-EU business be its own importer of record in the EU?
Usually not. The customs declarant must normally be established in the European Union. A non-established business imports through an indirect customs representative: an EU-established party that files the declaration in its own name, on the importer’s behalf, and shares liability for the customs debt. The United Kingdom applies the same idea through an indirect agent. Switzerland is different: a foreign business can be the importer there, with the right identifiers and a Swiss fiscal representative for the VAT.
Austria
Available now 
Belgium
From 2027 Q1 
Bulgaria
From 2026 Q4 
Croatia
From 2027 Q1 
Cyprus
From 2026 Q4 
Czechia
Available now 
Denmark
From 2026 Oct 
Estonia
From 2026 Q4 
Finland
From 2026 Sep 
France
From 2027 Q1 
Germany
Available now 
Greece
From 2026 Q4 
Hungary
From 2026 Q4 
Ireland
Available now 
Italy
From 2026 Q4 
Latvia
From 2026 Q4 
Lithuania
From 2026 Q4 
Luxembourg
From 2026 Q4 
Malta
From 2026 Q4 
Netherlands
From 2026 Dec 
Poland
From 2026 Q4 
Portugal
From 2026 Q4 
Romania
From 2026 Q4 
Slovakia
Available now 
Slovenia
From 2026 Q4 
Spain
From 2026 Oct 
Sweden
Available now 
Switzerland
Available now 
United Kingdom
Available now Emblems shown in each country's national colours. Rollout timing for upcoming countries is indicative and not yet final.
Who can be the importer of record?
The answer decides everything downstream. It differs between the European Union, the United Kingdom and Switzerland, so it is worth thirty seconds before the country detail.
| Territory | Can you be your own importer of record without a local establishment? | What fills the gap |
|---|---|---|
| European Union | Usually not. The customs declarant must normally be established in the EU (Article 170(2) of the Union Customs Code). | An indirect customs representative established in the EU files in its own name on your behalf and shares the customs liability. Your business still appears on the declaration with its own EORI, which we arrange. |
| United Kingdom | Not in Great Britain, if you are not established there. A non-established importer acts through a customs agent appointed as an indirect agent (Section 21, Taxation (Cross-border Trade) Act 2018). | A UK-established indirect agent files in its own name and shares the liability. Northern Ireland follows the EU rules for goods under the Windsor Framework, so movements into Northern Ireland run on the XI EORI. |
| Switzerland | Yes, in principle. A foreign business can be the importer of record in Switzerland in its own name. | The business needs its own customs identity (a UID, and a GP-ID under the new Passar system), a Swiss fiscal representative for the VAT, and normally security towards the authorities. We set up all three. |
Four ways the import VAT can be handled
Import VAT is rarely a cost in the end. It is a cash flow and compliance question, and there are four ways to answer it. Which one fits depends on the market, the flow and the volumes. We recommend one and then run it.
| Route | Where it applies | What it does | What it needs |
|---|---|---|---|
| Deferred import VAT (postponed accounting) | Most EU states, the UK (Postponed VAT Accounting) and Switzerland (transfer procedure) | Import VAT is accounted for on a VAT return and deducted on the same return, so it nets to zero with no cash at the border. | A VAT registration in the market, and in many states a licence or authorisation. The country table shows each mechanism. |
| Limited fiscal representation | Netherlands and Belgium only | We import under our own licence and number, so you do not need a VAT registration of your own in that country. Import VAT is deferred and the onward supply is reported by us. | An agreement appointing us as your limited fiscal representative. |
| Customs procedure 42 | All EU states, for goods that move straight on to another EU country | The import itself is exempt from VAT, because it is immediately followed by an intra-Community supply. VAT is then due in the destination state under normal rules. | A VAT identity in the country of import, an EU-established declarant, and evidence the goods moved on. Some states ask for security, which we arrange. |
| Pay and recover | Germany, Italy, Greece, Malta, Cyprus and Bulgaria, where no general deferral exists | Import VAT is paid at clearance and recovered through the VAT return or a refund claim. A deferment account can soften the timing of the payment. | A recovery route set up before you ship: a registration, or a refund claim where you hold none. |
Where guarantees come into it
Authorities protect deferred or suspended tax with security. It arises at three points, and it is normal. In our structures the security generally sits with us, not with you: we hold the licences and the accounts, we arrange the guarantees behind them, and we price that into the service.
| Where security can arise | What it covers | Typical form and level |
|---|---|---|
| Customs deferment account | Duty, and in some states the import VAT, deferred after release. | A comprehensive guarantee under the Union Customs Code: a bank undertaking or a cash deposit, sized to the amounts deferred. Reductions and waivers exist for authorised operators. Switzerland asks security of foreign businesses, historically around twenty percent of sixty days of import VAT with a minimum of CHF 2,000. |
| Fiscal representation licences | The VAT the representative answers for on behalf of its clients. | Set per licence and per market. Statutory formulas exist in some states; the Netherlands, for example, sets it at five percent of the average monthly VAT base with a minimum of EUR 5,000. |
| Customs procedure 42 | The conditionally exempt import VAT, until the goods are shown to have left the country of import. | Most states ask nothing per import. A minority run a statutory security, Hungary and Estonia among them, and Italy takes security on request after risk analysis. It is released once the onward supply is evidenced. |
Reporting: what exists, and who files it
Every market attaches reporting to an import flow. You do not need to learn the forms; that is our work. It helps to know the five names you will hear, because they explain what is being filed on your behalf.
| Obligation | What it is | Who files it |
|---|---|---|
| VAT return | The periodic return where import VAT, deferred VAT and onward sales are reported. Monthly or quarterly in most markets. | We prepare and file it: under our own number in limited representation, or under your registration where you hold one. |
| EC Sales List | A listing of intra-Community supplies to VAT-registered customers in other EU states. | We file it whenever goods move on cross-border, including under customs procedure 42. |
| Intrastat | A statistical declaration of goods moving between EU states, above country thresholds. | We monitor the thresholds and file where required. |
| Transaction-level reporting | Control statements, SAF-T files and real-time invoice reporting that a growing number of states require alongside the return. | Ours to run in every state that requires it. |
What these rules mean
These are the concepts behind every cell in the table below. Each is defined once here. The matrix shows how each one applies in your market.
Importer of record is the term used for the party that acts as the importer or declarant during the customs procedure. It is the party that becomes legally responsible for the import; files the import declaration in its own name, pays any duty and import VAT, and answers to customs for the entries. In most territories the importer of record must hold a local establishment and can act on behalf of a non-established business.
Why it matters: If you are not established in the market, you usually cannot be your own importer of record, so the goods do not move until an established party takes the role.
When it matters: If you sell goods using Incoterms DDP or are moving goods you own into a country where you are not established.
An exporter of record is the term used for the party that acts as the exporter or declarant during the customs procedure. It is the party that becomes legally responsible for the export; files the export declaration in its own name, pays any export duty, takes on responsibility for export controls and licensing, and answers to customs for entries. In most territories the exporter of record must hold a local establishment and can act on behalf of a non-established business.
Why it matters: If you are not established in the market, you usually cannot be your own exporter of record, so the goods do not move until an established party takes the role.
When it matters: If you purchase goods using Incoterms EXW or are moving goods you own out of a country where you are not established.
Indirect customs representation is set out in Article 18 (2) of the Union Customs Code in the European Union, and in Section 21(1)(b) of the Taxation (Cross-border Trade) Act 2018 in Great Britain. Under the Northern Ireland Protocol, in force since January 2021 and since revised by the Windsor Framework, Northern Ireland remains aligned with European Union rules for trade in goods. Across this website, the United Kingdom refers to both Great Britain and Northern Ireland, even though the two are treated separately for customs. The representative files the customs declaration in its own name but on behalf of the importer, and is jointly and severally liable with the importer for the customs debt.
Why it matters: It is the route that lets a non-established business import without its own entity, but the joint liability is why many brokers will not offer it.
When it matters: A customs broker normally acts as a direct representative. It files in the client's name, and the customs debt stays with the client. Indirect representation is a different order of risk. The broker files in its own name. It then takes on joint and several liability for the customs debt, often for a client that is not established in the market and hard to pursue if something goes wrong. A broker usually runs a substantial business of its own, with its own clients and its own responsibilities, and a single liability of this kind could threaten the whole of it. That is why most brokers decline indirect representation, and it is where we come in. We act as the indirect representative in our own name and take on the liability, so the broker keeps the client and the clearance work without putting its own business on the line.
An EORI number (Economic Operators Registration and Identification) is the business identification number for customs in the European Union and the United Kingdom. Three identifiers exist. A GB EORI, issued by HMRC, covers Great Britain. An XI EORI, also issued by HMRC under the Windsor Framework, is used for Northern Ireland movements and is recognised in EU systems. Member states of the European Union issue EU EORI numbers for the Union itself. The applicable EORI is required to lodge customs declarations in a territory.
Why it matters: Without the right EORI for the territory, declarations cannot be filed. A GB EORI is not accepted in the European Union, and goods moving into Northern Ireland need the XI EORI, not an EU one. Holding an EORI does not by itself allow a non-established business to file in its own name; the declarant must still be established, which is the role we take.
A GP-ID is the business-partner identity for Swiss customs under the new Passar system. It replaces the previous ZAZ customs-account identity and is coupled to the business’s UID number; a foreign business without a Swiss UID registers in the federal ePortal using a DUNS number instead. Registration is not automatic. The old and new systems run in parallel until the final e-dec import declaration on 30 September 2027.
Why it matters: A GP-ID will be required to file declarations, and it gives a non-Swiss business a route to complete customs formalities in its own name.
When it matters: Existing businesses can keep filing on the current basis during the transition, and the customs authority recommends registering during 2026. Businesses without Swiss or Liechtenstein domicile should expect to lodge security.
Import VAT is normally paid in cash at the border and reclaimed later on the VAT return, which ties up money in between. Deferral lets the registered party account for the import VAT on a VAT return instead of paying it up front, and at the same time recover the VAT, so it nets to zero with no cash outlay. The mechanism and the conditions differ by country.
Why it matters: Without it, a non-resident importer can have a large amount of cash tied up on every shipment.
When it matters: Non-established businesses need to line up deferral before they import, or cash stays tied up until the setup is corrected or a refund procedure runs its course.
Local names: UK: Postponed VAT Accounting (PVA) · Switzerland: transfer procedure (Verlagerungsverfahren) and centralised settlement procedure (ZAZ) · Netherlands: Article 23 licence · Belgium: ET 14000 licence · France: reverse charge of import VAT (autoliquidation de la TVA à l'importation) · EU (general): reverse charge import VAT.
Customs procedure 42 is an EU regime for goods that are imported into one member state and move straight on to another. The import itself is exempt from VAT because it is immediately followed by an intra-Community supply; VAT is then due in the destination state under the normal rules. The importer must hold a VAT identity in the country of import, the declaration must show the VAT identities of the importer and the customer, and the onward movement must be evidenced.
Why it matters: Used well, it removes import VAT from the cash flow entirely on flows that transit the country of entry. Used badly, the exemption fails and the import VAT is assessed after the fact, sometimes with security demanded.
When it matters: Goods enter through one member state, for example through Rotterdam or Antwerp, and sell or ship onward to a customer in another.
A customs guarantee is security that a customs or tax authority holds against duty or VAT that has been deferred, suspended or conditionally exempted. In the EU, the comprehensive guarantee of the Union Customs Code backs deferment accounts. Some states also take security at the level of a fiscal representation licence, or for the conditionally exempt VAT under customs procedure 42.
Why it matters: Somebody has to post it before the goods flow. In our structures that is normally us, not you.
A fiscal representative is a locally established party that registers and reports VAT on behalf of a foreign business and is typically jointly responsible for the VAT. Some countries require one before a non-resident can register, though several carve out businesses from states with mutual-assistance agreements, the United Kingdom and Norway among them in parts of the EU. A business established in the EU never needs a fiscal representative to register in another EU member state.
Why it matters: Where it is required, a non-resident cannot register or recover VAT without appointing one, which adds cost and sometimes requires a guarantee.
Limited fiscal representation is a lighter form of representation used mainly for imports that are followed by an onward supply. The representative acts under its own licence, so the foreign business does not need its own VAT registration in that country. It is available only in Belgium and the Netherlands.
Why it matters: It lets a non-resident import and move goods without taking a full local VAT registration, which simplifies the setup.
The registration trigger is the point at which a business must register for VAT in a country. For a non-resident, the domestic revenue-based thresholds usually do not apply. Registration is generally required before the first taxable transaction, such as importing, holding stock, or making a local supply.
Why it matters: Getting this wrong means trading without a required registration, which brings penalties and blocks VAT recovery.
When it matters: EU and UK: no threshold for non-established businesses · Switzerland: registration once worldwide turnover reaches CHF 100,000.
The standard VAT rate is the default rate applied to most goods and services in a country. Reduced rates apply to certain categories where legislators have decided to stimulate certain consumption or reduce costs borne by consumers. Import VAT is charged at the standard rate of the country of import unless a reduced rate applies.
Why it matters: The rate sets how much cash is tied up at import before recovery, which is why a clean recovery route matters most in high-rate countries.
Local names: Rates across the markets covered run from Switzerland at the low end to Hungary at the high end. See the matrix for each country.
VAT returns are filed on a set cycle, most often monthly or quarterly, with the cycle sometimes depending on turnover. A periodic return reports all VAT, including the import VAT accounted for under a deferral scheme. Deadlines and frequencies are set by each country.
Why it matters: The frequency drives the compliance workload and how quickly recoverable VAT comes back to you.
The 13th Directive is the EU procedure that lets a business which is not established and not registered in the EU reclaim VAT it has incurred there. Recovery is often subject to reciprocity, meaning the claimant’s own country must offer EU businesses a similar refund. The UK and Switzerland run their own equivalent schemes.
Why it matters: It is the route to recover VAT where there is no local registration, but the reciprocity condition can decide whether a claim is possible at all.
Local names: EU: 13th Directive refund (Directive 86/560/EEC) · UK: VAT refund scheme for overseas businesses · Switzerland: VAT refund for foreign businesses.
Questions we hear
How we handle this for you
Reading the rules is one thing. Taking them on is another. We act as your importer of record, exporter of record and indirect customs representative, and we handle the VAT registration, fiscal representation, deferment and recovery that go with them. One established team takes the declaration and makes the VAT work, in the markets shown above. To see how each part fits, read our importer of record, exporter of record, indirect customs representation and VAT pages.
Customs and VAT, country by country
Expand any country to see how each rule applies there. Every status links up to its definition above.
All positions last verified: July 2026
Deferred import VAT mechanism: Postponed accounting through the tax account (import VAT settled on the return) where the conditions are met.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 20%
VAT return frequency: Monthly, or quarterly below EUR 100,000 turnover.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: ET 14000 licence; application required, not automatic.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction. Under limited fiscal representation no Belgian registration of your own is needed; the flow runs on our number.
Standard VAT rate: 21%
VAT return frequency: Monthly, with a quarterly option.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: No general deferral. Import VAT is paid at clearance and recovered on the return; a separate regime exists for approved investment projects only.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 20%
VAT return frequency: Monthly.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Postponed accounting on the return for registered importers; conditions apply.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 25%
VAT return frequency: Monthly, with a quarterly option.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: No deferral. Import VAT is paid at clearance and recovered on the return; warehousing is the only deferral-style route.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 19%
VAT return frequency: Quarterly.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Import VAT self-assessed on the return by registered importers.
Fiscal representation: No fiscal-representative institute exists in Czech law; a non-EU business registers directly.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 21%
VAT return frequency: Monthly, or quarterly for small taxpayers.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Import VAT accounted on the return, automatically, for registered businesses.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 25%
VAT return frequency: Monthly, quarterly or half-yearly by turnover.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Return-based accounting on authorisation for registered persons; the default is payment at customs.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 24%
VAT return frequency: Monthly.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Import VAT self-assessed on the return; the standard mechanism for registered importers.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 25.5%
VAT return frequency: Monthly, with quarterly or annual cycles for small taxpayers.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Automatic postponed accounting on the French return, compulsory for all VAT-registered importers.
Fiscal representation: Not required for businesses from states with a mutual-assistance agreement, the United Kingdom among them; otherwise an accredited representative is mandatory.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 20%
VAT return frequency: Monthly, or quarterly for very small VAT amounts.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: No accounting on the return. Import VAT is levied under customs rules; a deferment account with security shifts the payment date, and the VAT is then recovered on the return.
Fiscal representation: Not required for registration itself. Limited fiscal representation is optional for businesses only having non-taxable activities touching Germany, such as customs procedure 42.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 19%
VAT return frequency: Monthly or quarterly, plus an annual return.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: No deferral in practice. A licence exists only above EUR 100 million of annual imports with an onward-supply test, so ordinary importers pay at customs and recover on the return.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 24%
VAT return frequency: Monthly for double-entry books, quarterly otherwise.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Self-assessment of import VAT on the return under authorisation; conditions include monthly filing. Without the authorisation, import VAT is paid and recovered.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 27%
VAT return frequency: Monthly, quarterly or annual by turnover.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Postponed accounting on the return for traders registered for VAT and for Customs and Excise; not compulsory.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 23%
VAT return frequency: Bi-monthly (every two months) as standard.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: No general accounting on the return. Import VAT is treated as a border duty; deferment and guarantee routes shift the payment date, and a VAT warehouse can suspend it.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 22%
VAT return frequency: Monthly settlements, with quarterly communications and an annual return.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Return-based accounting under a special import regime, on authorisation.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 21%
VAT return frequency: Monthly, or quarterly for small taxpayers.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Import VAT offset on the return for registered importers, on authorisation.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 21%
VAT return frequency: Monthly, with a half-yearly option for the smallest.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Postponed accounting on authorisation from the tax authority.
Fiscal representation: Direct registration is accepted in practice; the authority may ask for a representative in specific cases.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 17%
VAT return frequency: Monthly, quarterly or annual by turnover.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: No accounting on the return. Payment at the border, or a payment deferment on approval; the VAT is recovered on the return.
Fiscal representation: Direct registration is common; the Commissioner may direct a representative in specific cases.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 18%
VAT return frequency: Quarterly.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: The Article 23 licence shifts import VAT to the return. A non-EU business reaches the licence through a fiscal representative; under limited representation one licence on our number covers our clients.
Fiscal representation: Not required for registration itself; a representative is needed in practice to hold the Article 23 import-deferral licence.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction. Under limited fiscal representation no Dutch registration of your own is needed; the flow runs on our number and licence.
Standard VAT rate: 21%
VAT return frequency: Quarterly, with a monthly option.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Settlement on the return under Article 33a for active payers with a clean tax status; the declaration runs through a customs representative or an AEO holder, and monthly filing applies.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 23%
VAT return frequency: Monthly (JPK_V7M), quarterly for small taxpayers.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Return-based option for monthly filers with a regularised status; opt-in in the prior month with a six-month commitment.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction. The standard rate shown is mainland; the Azores and Madeira apply lower rates.
Standard VAT rate: 23%
VAT return frequency: Monthly above EUR 650,000 turnover, otherwise quarterly.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Return-based only with a deferment certificate, tied to AEO status with centralised clearance or to import volumes; otherwise import VAT is paid at the border.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 21%
VAT return frequency: Monthly, or quarterly for small taxpayers.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Self-assessment exists but is closed to non-EU established importers: Slovak-established businesses since July 2025, EU-established businesses with a Slovak VAT number and AEO status since January 2026. The gap is filled through an EU-established structure such as ours.
Fiscal representation: Not a precondition for registration; a non-EU business registers directly, and the import-representative regimes are optional.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 23%
VAT return frequency: Monthly, or quarterly after a compliant first year.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Postponed accounting on the return for registered importers.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 22%
VAT return frequency: Monthly, or quarterly for small taxpayers.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Import VAT deferral on the return for monthly filers (REDEME or large businesses); the option is exercised in November for the following year.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction. The Canary Islands apply IGIC, not VAT.
Standard VAT rate: 21%
VAT return frequency: Monthly under REDEME, otherwise quarterly.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Import VAT accounted on the return; the standard mechanism for VAT-registered importers.
VAT registration trigger: No threshold for non-established businesses; register before the first taxable transaction (import, holding stock or local supply).
Standard VAT rate: 25%
VAT return frequency: Monthly, quarterly or annual by turnover.
13th-Directive refund: Conditional. Reciprocity may apply, depending on the claimant's country of establishment.
Deferred import VAT mechanism: Postponed VAT Accounting (PVA); elected per declaration, with no prior authorisation.
Fiscal representation: Not required for a non-established taxable person; HMRC may direct one in edge cases.
VAT registration trigger: No threshold for a non-established taxable person (NETP); register before the first taxable supply.
Standard VAT rate: 20%
VAT return frequency: Quarterly as standard, with a monthly option.
13th-Directive refund: Conditional. The route is the UK overseas-business refund scheme, and conditions apply.
Indirect representation: Required for a non-established importer in Great Britain. A customs agent acts as an indirect agent in its own name under Section 21 of the Taxation (Cross-border Trade) Act 2018 and shares the liability. Few brokers offer the role; it is the one our UK entity takes.
Deferred import VAT mechanism: The transfer procedure (Verlagerungsverfahren) moves import VAT to the return, on authorisation, and suits importers with a regular input-tax surplus. Otherwise import VAT is paid, deferred up to sixty days on account, and recovered on the return.
VAT registration trigger: Register once worldwide turnover reaches CHF 100,000. The customs identity moves to the GP-ID under Passar; the final e-dec import declaration is 30 September 2027.
Standard VAT rate: 8.1%
VAT return frequency: Quarterly as standard.
13th-Directive refund: Conditional. A refund scheme for foreign businesses exists, and reciprocity applies.
Indirect representation: Swiss customs law has no EU-style split between direct and indirect representation; a foreign business can be the importer in its own name, which is why no representative is required.
Reviewed by Occendra's indirect-tax team
Mikael W. · Founder & Head of Compliance · LL.M., specialisation in tax
See your market clearly, then let us handle it
The rules differ in every market, and they change. Tell us where you import and sell, and we will take on the declaration and the VAT, so a shipment moves and the VAT is recovered, not lost.