Requirements
There are some requirements for using fiscal representation. See below for information about incoterms, sales invoices and transfers of own goods.
Are you an online seller who uses EXW or FCA shipments to deliver your products to customers? If so, you may be at risk for paying Dutch VAT. At Neele-Vat, we can only offer you general fiscal representation (GFR) in these cases, as we do not provide limited fiscal representation (LFR). We strongly advise against selling EXW or FCA to your customers due to the high risk of VAT payment. However, if you do customs clear your goods with LFR by Neele-Vat, you can store them in a warehouse in the Netherlands and avoid direct payment of VAT. Keep in mind that moving the goods to a different warehouse not controlled by Neele-Vat will require payment of Dutch VAT. Our team can assist you in meeting the requirements for sales invoices and transferring your own goods to another EU country. Contact us for more information on how we can help you with your fiscal representation needs
EXW/FCA Shipments
Are you considering using EXW or FCA shipments to sell goods to your customers? If so, please note that we can only offer general fiscal representation (GFR) and not limited fiscal representation (LFR) in these cases. Since your customer is responsible for organizing transport, these shipments are considered a delivery in the Netherlands, meaning that Dutch VAT must be paid. However, there is a way to avoid VAT payment by having your customer sign a “collection declaration” and providing two additional documents to prove delivery outside the Netherlands. These documents typically include a signed CMR and a transport invoice, which you will need to request from your customer. The collection declaration must be completed and signed by your customer before the goods can be picked up in the Netherlands. It’s important to note that if the documentation is not in order, the Dutch tax authorities can charge VAT up to 5 years after the shipment. Given this risk, we strongly advise against selling EXW or FCA to your customers.
Transfer of own goods
It is possible to transport your goods to your own company in another EU country. This could be the country in which your business is established or another EU country where you would like to store your goods. This does mean that you need to be in the possession of a VAT number in every country where you want to store your goods. This transfer of own goods is called a fictitious intra-Community supply. It will be handled by us as a “normal” intra-Community supply. We will transfer the VAT from the Netherlands to your foreign EU VAT number. The value of the goods is dependent on the customs clearance and will be calculated from the customs value and the import duties.
Storage in the Netherlands
When your goods have gone through customs clearance with limited fiscal representation (LFR) by Neele-Vat, they can be stored in a warehouse in the Netherlands that is arranged by Neele-Vat, allowing you to avoid direct payment of VAT. However, if you decide to move the goods to a different warehouse in the Netherlands that is not controlled by Neele-Vat, you will be required to pay Dutch VAT on those goods, which can be either 21% or 9%.
If you have a general fiscal representation (GFR) contract with Neele-Vat, you can move your goods to a Dutch warehouse that is not controlled by Neele-Vat without having to pay VAT. This transfer of your own goods within the Netherlands does not need to be declared to the Dutch tax authorities. However, please keep in mind that if you sell or deliver goods from the warehouse, you will need to declare it in your subsequent sale or delivery.
