Applying for VAT identification numbers in the European Union

When is VAT registration required?

VAT registration obligations depend on the nature of business activities, the countries involved, and various threshold limits. Understanding when registration becomes mandatory prevents both compliance failures and unnecessary administrative burdens from premature registration.

Domestic registration requirements vary significantly between member states. Some countries require registration from the first taxable supply regardless of value. Germany, for example, has no small business exemption threshold for VAT registration, meaning all businesses making taxable supplies must register. Other countries permit small businesses to operate without VAT registration until reaching turnover limits. France exempts businesses below certain annual thresholds, though different limits apply to goods sales versus services.

Cross-border activities often trigger registration obligations independent of domestic thresholds. Holding stock in a country typically requires registration there, even if no sales threshold has been reached. Organising paid events with admission charges creates a place of supply in the event location country. Installing or assembling goods may shift the supply location to the country of installation. Each of these scenarios needs individual assessment against the specific rules of the countries involved.

The One-Stop Shop schemes have reduced but not eliminated registration requirements for distance sellers. Businesses using OSS for B2C sales avoid registering in destination countries for those specific supplies. However, OSS does not cover B2B transactions, supplies involving transport or installation, or activities that create an establishment in another country. Businesses with more complex supply chains often still need multiple registrations despite OSS availability.

General registration procedures

While each member state maintains its own registration system, common elements appear across jurisdictions. Understanding these typical requirements helps prepare documentation before engaging with any specific tax authority and sets realistic expectations for the registration timeline.

Application forms request basic information about the business: legal name, trading names, registered address, directors or officers, nature of business activities, and expected turnover. For companies, the forms typically require company registration numbers, articles of incorporation, and proof of directors' identities. For sole traders, personal identification documents and proof of address are standard requirements.

Foreign businesses registering without a local establishment usually need to appoint a fiscal representative or tax agent, depending on the specific country's requirements. Fiscal representatives assume joint liability for the VAT obligations, making them appropriate for situations where the tax authority needs recourse against someone within their jurisdiction. Tax agents provide administrative services without accepting liability. Some countries differentiate these roles clearly; others use the terms interchangeably.

Supporting documentation beyond the application form commonly includes: certificates of incorporation or registration from the home country, evidence of the business activities triggering registration (contracts, invoices, proof of stock location), bank account details for future refunds, and any existing VAT registration certificates from other countries. Documents not in the local language typically require certified translation, adding time and cost to the registration process.

Country-specific registration guidance

Germany

German VAT registration operates through the Bundeszentralamt für Steuern (Federal Central Tax Office) for initial registration, with ongoing administration handled by the local Finanzamt (tax office). Foreign businesses without a German establishment submit form USt 1 TI along with supporting documentation. The form is available in German, though English guidance exists.

Processing times have historically been lengthy, sometimes extending to several months, particularly for businesses from outside the EU. Incomplete applications or unclear documentation significantly extend this timeline. Once registered, businesses receive a VAT registration certificate (Umsatzsteuer-Identifikationsnummer Bescheinigung) confirming their DE-prefixed number.

Germany does not generally require fiscal representation for EU businesses, but non-EU businesses without an EU establishment must appoint a fiscal representative who accepts joint liability. The representative must be established in Germany and registered for VAT themselves.

France

French VAT registration is administered by the Service des Impôts des Entreprises (SIE), with foreign businesses typically assigned to the specialised non-resident office in Paris. The standard registration form is cerfa n°11768, available through the service-public.fr portal.

Required documents include proof of company existence (certified copies of articles of incorporation), identification documents for directors, evidence of taxable activities in France, and power of attorney if using a representative. All documents must be in French or accompanied by sworn translations.

Processing typically takes four to eight weeks for EU applicants with complete documentation. Non-EU applicants may experience longer delays. French registration simultaneously provides the TVA intracommunautaire (intra-Community VAT number) and the SIREN number used for broader commercial identification purposes.

Italy

Italian VAT registration requires submission to the Agenzia delle Entrate through their online portal or via physical submission to the competent provincial office. Foreign businesses use form AA7/10 for companies or AA9/12 for individuals and partnerships.

Italy requires fiscal representation for businesses without an Italian establishment, with exceptions for businesses established in countries having mutual assistance agreements with Italy. The fiscal representative must be an Italian-resident entity or individual accepting joint liability for the foreign business's Italian VAT obligations.

The registration process typically takes one to three weeks once all documentation is correctly submitted. Italian VAT numbers activate immediately upon successful registration, appearing in the VIES system shortly thereafter. Quarterly reporting applies to most registered businesses, with monthly reporting for larger operations.

Spain

Spanish VAT registration operates through the Agencia Tributaria using form 036 (censal declaration) for most businesses or simplified form 037 for certain small businesses. Foreign businesses register at the Delegación Central de Grandes Contribuyentes in Madrid or the appropriate provincial delegation.

Documentation requirements include NIE (foreigner identification number) for individual applicants, apostilled and translated company documents for corporate applicants, and proof of planned economic activity in Spain. Appointment of a representative is mandatory for businesses not established within the EU.

Registration processing varies considerably, from a few days for straightforward EU business applications to several weeks for more complex cases involving non-EU entities or unusual business structures. Once registered, businesses must comply with the SII (Suministro Inmediato de Información) real-time reporting requirements if they exceed certain thresholds.

Netherlands

Dutch VAT registration is handled by the Belastingdienst (tax authority). Foreign businesses submit a registration request describing their activities and providing supporting documentation. The registration form is available through the Belastingdienst website and can be submitted online for many business types.

The Netherlands does not require fiscal representation for EU businesses. Non-EU businesses may need representation depending on the nature of activities and any treaty arrangements between their country and the Netherlands. When required, the representative must be established in the Netherlands.

Processing times are generally efficient, often under two weeks for complete applications from EU businesses. The BTW-nummer issued follows the format NL plus a number sequence plus B plus two digits, with the B indicating it is a VAT registration number. Registered businesses join the Kamer van Koophandel register if not already registered there.

Poland

Polish VAT registration requires submission of VAT-R form to the appropriate tax office. Foreign businesses without a Polish establishment submit to the Second Tax Office Warsaw-Śródmieście, which handles non-resident registrations centrally.

Poland requires fiscal representation for businesses established outside the EU unless their country has an appropriate mutual assistance agreement. The representative assumes joint liability for the foreign business's Polish VAT obligations and must be a Polish entity or individual registered for VAT.

Processing typically takes two to four weeks. Once registered, businesses appear on the White List (Wykaz podatników VAT), which is publicly searchable and displays not only VAT status but also registered bank accounts. Customers making payments to accounts not on the White List may lose their right to input VAT deduction, making White List verification important for Polish B2B transactions.

Common registration mistakes and how to avoid them

Many VAT registration applications fail or experience delays due to avoidable errors. Understanding common pitfalls helps prepare applications that proceed smoothly through the administrative process.

Incomplete documentation causes more delays than any other single factor. Tax authorities return applications lacking required attachments, certified translations, or apostilles. Before submission, verify that every document listed on the application form is included and that each meets the specified requirements for certification or authentication.

Incorrect activity descriptions can result in registration for the wrong VAT scheme or trigger unnecessary investigations. Describe business activities accurately and specifically. If selling goods, specify whether you will hold stock locally, sell to businesses or consumers, and import from outside the EU. For services, clarify the nature of services and typical customer profile.

Timing issues affect registration in several ways. Applying too early, before having any genuine activities requiring registration, may prompt tax authorities to question the application or defer processing. Applying too late, after taxable activities have already occurred, creates compliance gaps that may require amended returns and potentially attract penalties.

Representative selection errors cause ongoing problems. Appointing an unqualified representative, one in the wrong country, or one not properly registered themselves invalidates the registration. Verify your representative's credentials, registration status, and authority to act before including them in your application.

Bank account information must be current and accurate. Tax authorities use registered bank accounts for refund payments, and some countries like Poland require specific bank accounts for receiving payments from customers. Providing incorrect bank details delays refunds and may create compliance issues with payment rules.

Post-registration obligations

Receiving a VAT number marks the beginning rather than the end of compliance responsibilities. Each registration creates ongoing filing and payment obligations that must be maintained to keep the registration active and in good standing.

Return filing frequencies vary by country and sometimes by turnover level. Monthly returns are common for larger businesses or those with high transaction volumes. Quarterly returns suit smaller operations with fewer transactions to report. Some countries offer annual returns for very small businesses. Know your filing schedule from the outset and calendar the deadlines.

Payment deadlines typically align with return due dates, though some countries require estimated payments in advance or impose different payment schedules. Late payments attract interest and potentially penalties even when returns are filed correctly. Set up payment mechanisms appropriate for the country, whether direct debit, bank transfer, or online payment systems.

Intrastat and EC Sales List reporting requirements apply to businesses exceeding certain thresholds for intra-Community trade. These are separate from VAT returns but use data from the same transactions. Check threshold levels for each country where you are registered and implement data collection processes that support all required reporting.

Registration details must be kept current. Notify the relevant tax authorities of address changes, director changes, changes in business activities, and any other material modifications to the information provided at registration. Failure to maintain accurate registration details can jeopardise the registration and create compliance issues.

Deregistration and dormancy

When business activities in a country cease, deregistration may be appropriate to eliminate ongoing filing obligations. However, deregistration requires careful timing and proper procedure to avoid creating historic compliance gaps or losing input tax recovery rights.

Voluntary deregistration is generally possible when taxable activities have ceased and no future activities are planned. Submit deregistration requests to the relevant tax authority, typically using prescribed forms. Outstanding returns must be filed and any VAT liability paid before the registration can be cancelled. Some countries require filing final returns up to a specified period after deregistration.

Involuntary deregistration occurs when tax authorities cancel registrations due to non-compliance, extended inactivity, or failure to respond to correspondence. Such cancellations can create problems if the business later needs to re-register or if the cancellation date differs from when activities actually ceased.

Dormant registrations, where filing obligations continue but returns show no activity, may be appropriate for businesses expecting to resume activities in the future. This approach maintains the registration for quick reactivation but still requires regular return submission. Evaluate whether maintaining dormancy is more or less burdensome than deregistering and re-registering later.