VAT for E-commerce in the EU

A complete guide to EU VAT obligations for Estonian online sellers — place of supply rules, the 2021 reform, B2B reverse charge, IOSS for imports, marketplace deemed supplier rules, and every threshold that matters.

Place of Supply €10K Threshold OSS IOSS Reverse Charge Deemed Supplier Digital Services
€10K EU B2C OSS Trigger
€150 IOSS Goods Threshold
27 EU VAT Rate Sets
2021 Reform Effective
30d OSS Filing Window
0% B2B Reverse Charge

5 Key Takeaways From This Page

Place of supply determines which country’s VAT applies
For physical goods, it is usually where the goods are located when control transfers. For services, it depends on whether the customer is a business or consumer. Getting this wrong means charging the wrong rate — or failing to charge at all.
B2B and B2C are fundamentally different VAT scenarios
Selling to a VAT-registered business in Germany triggers reverse charge — you charge 0% and the client accounts for their own VAT. Selling to a German consumer means you owe German VAT. The buyer type determines everything.
The location of your stock determines your VAT registration obligations
Stock held in an EU warehouse — even via Amazon FBA — creates a local VAT presence. OSS does not cover sales where both the goods and the buyer are in the same EU country. Warehouse locations and VAT registrations must align.
Marketplaces collect VAT for you in many scenarios — but not all
After the 2021 reform, Amazon, Etsy and other EU marketplaces act as deemed supplier for many cross-border B2C sales. They collect and remit VAT — but specific conditions apply. Understanding which transactions they cover prevents double-charging.
Digital services follow different place-of-supply rules
Electronically supplied services (e-books, software downloads, streaming, SaaS) have their own place-of-supply rule — always where the consumer is located. This rule applies regardless of whether you use a marketplace or sell direct.

What EU VAT rules apply to an Estonian e-commerce business? An Estonian OÜ selling goods or digital products across the EU faces a layered VAT framework: Estonian registration for domestic sales, OSS for cross-border B2C sales above €10,000, IOSS for imports of goods under €150, reverse charge for all EU B2B sales, and potentially local VAT registration in countries where stock is held. This page explains every layer — from first principles to the specific rules for physical goods, digital services, and marketplace sales.

Section 1 — The 2021 EU VAT Reform: What Changed and Why It Matters

How the Single EU VAT Area replaced 27 national thresholds and created OSS as the compliance mechanism

Before 1 July 2021: The Old System

Before the reform, each EU member state had its own distance-selling threshold — the revenue level above which a seller from another EU country had to register for VAT locally and charge local VAT. Thresholds ranged from €35,000 (Germany, Netherlands, Luxembourg) to €100,000 (the UK while still in the EU). Below the threshold, the seller charged their home country’s VAT (22% Estonian VAT) on all EU B2C sales.

System Distance-Selling Thresholds VAT on EU B2C Sales Below Threshold VAT on EU B2C Sales Above Threshold
Pre-2021 (old) 27 different thresholds (€35K–€100K per country) Home country VAT (22% Estonian) Local country VAT — local registration required
Post-2021 (current) Single EU-wide threshold of €10,000 total B2C Home country VAT (if below €10K total EU B2C) Destination country VAT — use OSS or register locally
What the Reform Created — Four New Mechanisms
🔄 OSS (One-Stop-Shop) | 📦 IOSS (Import OSS) | 🏪 Deemed Supplier Rules | 🗑️ Abolition of €22 Import Exemption

Section 2 — Place of Supply: Physical Goods

The rules that determine which country’s VAT applies to each goods transaction

The General Rule for Physical Goods

For physical goods, the place of supply is generally the location of the goods at the time control transfers to the buyer. The distance-selling rule states that when goods are dispatched from one EU country to a buyer in another EU country, the place of supply moves to the destination country for B2C sales above the €10,000 threshold.

The Critical FBA Warehouse Exception
When you use Amazon FBA and your goods are stored in a German warehouse, a sale to a German consumer is not a distance sale from Estonia — it is a domestic German sale. This transaction is completely outside the OSS scheme and requires a German VAT registration.

Section 3 — Place of Supply: Digital Services and E-content

Special rules for electronically supplied services — what qualifies and how VAT applies

What Counts as an Electronically Supplied Service

Electronically supplied services (ESS) have their own place-of-supply rule that overrides the general service rule. For ESS, the place of supply is always where the consumer is located — regardless of where the seller is established or where the service is technically delivered from.

The ‘minimal human intervention’ test
If your digital product requires significant human input per customer delivery — a custom design, a one-to-one coaching call — it is not ESS. If it is automated delivery of a standardised product (a download, an access key), it is ESS.

Section 4 — The €10,000 EU B2C Threshold

How to measure it, what counts, what happens when you cross it, and the decision to register early

Exactly What the Threshold Measures

The €10,000 threshold applies to the total value of cross-border B2C supplies of goods and electronically supplied services to consumers in other EU member states. It is an EU-wide cumulative threshold — all EU countries added together, not any individual country.

Scenario EU B2C Sales OSS Required? Action
New seller €0 No Charge 22% Estonian VAT on all EU B2C sales
Small seller €6,500 Optional May choose to register OSS voluntarily
Crosses €10K mid-year €10,001 REQUIRED Register for OSS immediately
Established seller €45,000 Active File quarterly OSS return

Section 5 — B2B Reverse Charge: Selling to EU Businesses

Why 0% is the correct rate on EU B2B invoices, how to verify the buyer, and what happens if verification fails

How Reverse Charge Works

When you supply goods or services to a VAT-registered business in another EU country, you charge 0% VAT. The VAT is not lost — it is ‘reversed’: the buyer is responsible for declaring the VAT in their own country as if they had supplied the service to themselves.

1
Go to VIES
2
Enter VAT Number
3
Check the Result
4
Screenshot the Check
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Issue Zero-Rated Invoice
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Declare on KMD

Section 6 — IOSS: Import VAT for Low-Value Goods

When to use IOSS, how it simplifies customs, and whether it makes sense for your business model

What IOSS Is and Who Needs It

The Import One-Stop-Shop (IOSS) is a scheme for selling physical goods valued at €150 or less that are imported from outside the EU directly to EU consumers. With IOSS, the seller collects VAT at the point of sale (at checkout), declares it monthly, and customs clearance is simplified because the VAT is already accounted for.

1
Checkout
2
Order
3
Delivery
4
Monthly Return
IOSS and marketplaces — who holds the IOSS number?
If you sell through Amazon or Etsy, and the marketplace is the deemed supplier, the marketplace holds the IOSS number — not you. You only need your own IOSS if you sell directly through your own website.

Section 7 — Marketplace Deemed Supplier Rules

When Amazon, Etsy, and Zalando collect VAT on your behalf — and when they do not

The Deemed Supplier Framework

Under the 2021 EU VAT reform, online marketplaces are treated as ‘deemed suppliers’ for VAT purposes on certain transactions. When the marketplace is the deemed supplier, it collects VAT from the buyer and remits it — you do not charge or remit VAT on those specific transactions.

How it appears in your accounts
Record gross sale as revenue. No VAT liability on your balance sheet for these transactions. The marketplace fee is recorded as COGS.

Section 8 — EU VAT Compliance Calendar

Every filing obligation, deadline, and penalty for an Estonian e-commerce business

Annual EU VAT Filing Calendar

Return Frequency Deadline After Period End What It Covers Penalty for Late Filing
Estonian KMD Monthly 20th of following month Estonian domestic VAT: output minus input Up to 3% of VAT due; min €30
OSS Return Quarterly 30 days after quarter end EU cross-border B2C goods and services sales €250 + 0.06%/day interest
IOSS Return Monthly End of following month Imports ≤ €150 to EU consumers IOSS deregistration risk

Frequently Asked Questions

Yes — the two apply to different transaction types and cannot be mixed. OSS covers cross-border B2C sales of goods from EU warehouses and electronically supplied services to EU consumers. IOSS covers specifically physical goods valued at €150 or less imported from outside the EU to EU consumers. If you sell a digital download AND a physical product in the same order, and the physical product is shipped from outside the EU, you need IOSS for the physical product value and OSS for the digital element. Your checkout system needs to handle these separately — most major platforms (Shopify, WooCommerce) support this with appropriate tax configuration.

A cross-border return requires a credit note referencing the original invoice. The credit note reduces your OSS liability for the quarter in which the credit note is issued. If you already filed and paid the Q1 OSS return and a return comes in Q2, you deduct it from your Q2 OSS liability for France — not by amending the Q1 return. If a full quarter’s returns create a net negative OSS position for a specific country (more VAT credited than collected), you can either carry it forward as a credit against future quarters or request a refund through the correction mechanism. The credit note itself is issued in the month of return, and your inventory accounting (restoring stock) happens at the same time.

The shipping address is the primary basis for determining the buyer’s country for B2C VAT purposes — and Shopify captures this automatically. However, for digital goods (downloads), the customer’s location should also be cross-referenced against IP address for anti-avoidance purposes (some buyers use VPNs to access content in different jurisdictions). Shopify Tax and third-party tax apps like TaxJar or Avalara can automate the VAT rate selection based on shipping address. For any business with significant EU B2C volume, configuring Shopify Tax correctly is essential — manual rate selection at checkout scale is not feasible.

At €9,800 you are below the €10,000 threshold and registration is not mandatory — you can continue charging 22% Estonian VAT on all EU B2C sales. However, if your EU B2C sales are growing and you expect to cross €10,000 during the year, consider registering for OSS proactively. The reason: once you cross the threshold mid-year, you must immediately charge destination-country VAT on all subsequent EU B2C sales — and may need to adjust invoices already issued in the same tax year. Registering voluntarily before you reach the threshold means you never have to make that adjustment and your billing system is configured correctly from the start.

Estonian VAT registration (getting an EE VAT number) is your primary registration for all Estonian and EU tax purposes. The OSS and IOSS registrations are add-ons within the EMTA portal — they do not require a separate VAT registration but do require you to already hold an Estonian VAT number. The sequence is: first register for Estonian VAT (mandatory above €40,000 turnover, voluntary below), then register for OSS or IOSS within the same EMTA e-Tax portal session. Your Estonian VAT number is used for all EU filings. You do not need a separate VAT number for OSS or IOSS — your existing EE number covers both.

Need help navigating EU VAT for your Estonian online store?

Book a free 30-minute consultation. We assess your current VAT obligations, set up OSS or IOSS registration, and handle every filing so you can sell across Europe without compliance risk.

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