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1. Background<\/h2>\n
The client was a US-based business selling physical products through Amazon and Shopify.<\/p>\n
The group had recently acquired a German company that was already a hellotax client. The German business had its own VAT compliance account and would continue operating separately.<\/p>\n
However, the planned European VAT expansion was connected to the US parent company.<\/p>\n
At the beginning of the project, the client was considering registrations and potential stock storage in Germany, France, Poland, the Netherlands, Italy and Spain. Switzerland was also discussed as a possible future market.<\/p>\n
The US company already had a Spanish VAT registration managed by another provider. It also had a separate UK VAT arrangement.<\/p>\n
This created a fragmented compliance structure involving several countries, companies and service providers. The client needed a practical multi-country VAT registration plan that focused on its immediate operational requirements.<\/p>\n
2. The challenge: Multi-country VAT registration for US sellers<\/h2>\n
The central challenge was not simply submitting several VAT applications.<\/p>\n
To organise multi-country VAT registration for US sellers correctly, hellotax first had to understand how the client\u2019s European activities would be structured.<\/p>\n
The following questions had to be resolved:<\/p>\n
- \n
- Which legal entity would own the inventory?<\/li>\n
- Which company would make the Amazon and Shopify sales?<\/li>\n
- In which countries would goods be stored?<\/li>\n
- Which VAT registrations were new?<\/li>\n
- Should the existing Spanish VAT number be transferred?<\/li>\n
- Would fiscal representation be necessary?<\/li>\n
- Could the Spanish EORI number be used in the Netherlands?<\/li>\n
- Which countries should be included in the first phase?<\/li>\n<\/ul>\n
The existence of both a US parent company and a German subsidiary was particularly important.<\/p>\n
A VAT number belongs to a specific legal entity. The company named on the registration should normally be the entity that owns the goods, makes the taxable supplies and appears on the relevant invoices.<\/p>\n
Registering the wrong company could have created inconsistencies between the client\u2019s VAT returns, customs declarations, Amazon accounts and accounting records.<\/p>\n
3. Why the European VAT expansion required early planning<\/h2>\n
The client wanted to begin its European VAT expansion as soon as possible.<\/p>\n
However, moving stock into another country can create VAT obligations before the business generates significant local sales.<\/p>\n
When goods are stored and dispatched from an EU warehouse, a foreign seller will generally require a local VAT registration. This can apply when stock is held in:<\/p>\n
- \n
- Amazon fulfilment centres<\/li>\n
- Third-party logistics warehouses<\/li>\n
- Warehouses operated by distributors<\/li>\n
- The seller\u2019s own local facilities<\/li>\n<\/ul>\n
For Amazon sellers, the VAT footprint is often determined by where Amazon is authorised to store inventory, not only by where customers are located.<\/p>\n
Our guide to Amazon FBA VAT compliance<\/a> explains how foreign warehouse storage can create additional registration and reporting obligations.<\/p>\n
The company therefore needed to coordinate its European VAT expansion with its fulfilment plans. Moving stock before the correct VAT registrations were obtained could have resulted in backdated filings, tax authority correspondence and additional costs.<\/p>\n
4. Defining the multi-country VAT registration strategy<\/h2>\n
The client\u2019s original list of countries changed during the consultation process.<\/p>\n
At different stages, the company considered France, Poland, Germany, the Netherlands, Italy, Spain and Switzerland.<\/p>\n
Instead of creating registrations in every potential market, hellotax helped the client focus on the countries connected to its immediate operations.<\/p>\n
The initial proposal covered:<\/p>\n
- \n
- Germany<\/li>\n
- France<\/li>\n
- Spain<\/li>\n
- The Netherlands<\/li>\n<\/ul>\n
Spain was included because the client already had a Spanish VAT number and was considering transferring its ongoing returns to hellotax.<\/p>\n
The company later decided to postpone the Spanish provider switch. The final multi-country VAT registration package therefore covered:<\/p>\n
- \n
- Germany<\/li>\n
- France<\/li>\n
- The Netherlands<\/li>\n<\/ul>\n
Italy and Switzerland were also removed from the immediate project.<\/p>\n
This gave the client a focused structure for its European VAT expansion while avoiding registrations and filing costs in countries that were not yet operational priorities.<\/p>\n
5. Separating the US parent company from the German subsidiary<\/h2>\n
An essential step in multi-country VAT registration for US sellers is identifying the correct legal entity.<\/p>\n
The German company acquired by the client already had its own account with hellotax and would continue using its existing compliance setup.<\/p>\n
The new registrations in Germany, France and the Netherlands were required for the US parent company.<\/p>\n
The US company therefore needed separate:<\/p>\n
- \n
- VAT registrations<\/li>\n
- VAT reporting records<\/li>\n
- Supporting company documents<\/li>\n
- Marketplace transaction data<\/li>\n
- Tax authority correspondence<\/li>\n
- Compliance processes<\/li>\n<\/ul>\n
Keeping the companies separate was necessary even though they belonged to the same corporate group.<\/p>\n
A parent company cannot normally use a subsidiary\u2019s VAT number for its own taxable activities. Each legal entity must account for the transactions it carries out.<\/p>\n
This issue is particularly important when a European VAT expansion follows an acquisition. Purchasing a company does not automatically transfer or extend its VAT numbers to the acquiring parent company.<\/p>\n
6. Planning registrations around European stock locations<\/h2>\n
The client used both Amazon and Shopify and was considering storing inventory in several EU countries.<\/p>\n
Its multi-country VAT registration requirements therefore depended heavily on where the goods would be located and which company would control them.<\/p>\n
For an Amazon seller, a local VAT number will normally be required when Amazon stores and dispatches the seller\u2019s goods from a warehouse in that country.<\/p>\n
For example, storing goods in a German Amazon warehouse usually creates German VAT registration and filing obligations. Our guide to Amazon VAT in Germany<\/a> explains these requirements in more detail.<\/p>\n
The same principle can apply when stock is stored in France or the Netherlands.<\/p>\n
The client\u2019s Shopify activity also had to be included in the European VAT expansion plan. Shopify is a sales platform, but the VAT treatment depends on:<\/p>\n
- \n
- Where the goods are stored<\/li>\n
- Where the goods are dispatched from<\/li>\n
- Where the customer is located<\/li>\n
- Which company makes the sale<\/li>\n
- Whether the transaction is domestic or cross-border<\/li>\n
- Whether the sale qualifies for OSS reporting<\/li>\n<\/ul>\n
By reviewing Amazon and Shopify together, hellotax could create a multi-country VAT registration structure covering the client\u2019s complete e-commerce activity.<\/p>\n
7. Understanding the role of OSS<\/h2>\n
OSS can simplify the reporting of certain cross-border B2C sales within the EU.<\/p>\n
However, OSS does not replace local VAT registrations in countries where a seller holds stock and makes domestic supplies.<\/p>\n
A multi-country VAT registration structure may therefore include:<\/p>\n
- \n
- Local VAT returns in stock-storage countries<\/li>\n
- OSS returns for qualifying cross-border B2C sales<\/li>\n
- Intra-Community reporting for stock transfers<\/li>\n
- Import VAT and customs declarations<\/li>\n<\/ul>\n
The exact reporting route depends on the movement of the goods and the type of transaction.<\/p>\n
Our guide to OSS for US sellers<\/a> explains how OSS interacts with local stock, imports and domestic VAT registrations.<\/p>\n
For this client, the European VAT expansion first had to be designed around the planned inventory locations. OSS could then be applied to the sales that qualified for centralised reporting.<\/p>\n
8. Clarifying fiscal representation<\/h2>\n
Fiscal representation can be an important cost and compliance factor in multi-country VAT registration for US sellers.<\/p>\n
Certain EU countries may require businesses established outside the EU to appoint a fiscal representative. Depending on the jurisdiction, the representative may communicate with the tax authority and share responsibility for the seller\u2019s VAT liabilities.<\/p>\n
The original hellotax proposal therefore separated normal VAT compliance charges from potential fiscal representation costs.<\/p>\n
France was particularly relevant because the client planned to sell there through Amazon.<\/p>\n
Fiscal representation can involve additional:<\/p>\n
- \n
- Service fees<\/li>\n
- Company documentation<\/li>\n
- Powers of attorney<\/li>\n
- Financial guarantees<\/li>\n
- Compliance checks<\/li>\n<\/ul>\n
These requirements should be identified during the planning stage of a European VAT expansion.<\/p>\n
Sellers considering French stock storage can find more information in our guide to VAT registration in France<\/a>.<\/p>\n
9. Resolving the Dutch EORI question<\/h2>\n
After confirming the VAT registrations in Germany, France and the Netherlands, the client asked whether it also required a Dutch EORI number.<\/p>\n
EORI stands for Economic Operators Registration and Identification. It is used to identify businesses involved in EU customs procedures.<\/p>\n
VAT registration and EORI registration are separate processes:<\/p>\n
- \n
- A VAT number is used for VAT reporting and invoicing.<\/li>\n
- An EORI number is used for customs declarations and import or export activities.<\/li>\n<\/ul>\n
The client already had a Spanish VAT registration and had previously imported goods into Spain.<\/p>\n
hellotax advised the company to check whether it had already received a Spanish EORI number. The client reviewed its records and found an existing Spanish EORI certificate.<\/p>\n
An EORI number issued by one EU Member State is generally recognised throughout the EU. A company does not normally need a separate EORI number in every country included in its European VAT expansion.<\/p>\n
The European Commission provides further information about the EORI system for EU customs procedures<\/a>.<\/p>\n
However, the client was also advised to confirm its customs setup with its broker because the correct treatment could depend on:<\/p>\n
- \n
- The importer of record<\/li>\n
- The entity named on the customs declaration<\/li>\n
- The customs authorisation held by the broker<\/li>\n
- The country where the goods enter the EU<\/li>\n
- The customs procedure being used<\/li>\n<\/ul>\n
This allowed the business to avoid assuming that a duplicate EORI registration was automatically required.<\/p>\n
10. The implementation package<\/h2>\n
The client selected an annual multi-country VAT registration and compliance package for Germany, France and the Netherlands.<\/p>\n
The service scope included:<\/p>\n
- \n
- VAT registration or takeover support<\/li>\n
- Periodic VAT returns<\/li>\n
- Annual VAT returns where required<\/li>\n
- Reporting of relevant intra-Community transactions<\/li>\n
- Support from local accountants<\/li>\n
- A dedicated account manager<\/li>\n
- Access to hellotax software<\/li>\n
- Support across Amazon and Shopify<\/li>\n
- Management of tax authority correspondence<\/li>\n
- Translation of relevant correspondence into English<\/li>\n<\/ul>\n
The annual contract value recorded for the three-country package was \u20ac4,164.<\/p>\n
This amount reflected the specific scope agreed with the client. It should not be treated as a standard price for all multi-country VAT registration projects because costs depend on the countries, filing frequencies, fiscal representation requirements and existing compliance setup.<\/p>\n