VAT, bookkeeping and payroll
Fiscal Representative in the Netherlands for Foreign Importers and Sellers
We check whether you need one, then arrange the licence, the security and the article 23 permit: import VAT on the return, not at Customs.
- Licence request: handled within 8 weeks (Belastingdienst service standard)
- Security: 5 percent of the monthly VAT base, minimum EUR 5,000
- Article 23: import VAT on the return, not paid at Customs
What's included
A fiscal representative (fiscaal vertegenwoordiger, or tax representative) acts in your company's name for the VAT return, payment and ICP declaration (art. 33g(1) Wet OB, in force from 1 January 2026). We arrange it end to end.
The need test
Whether your Dutch customers already owe the VAT under the reverse charge (art. 12(3) Wet OB). Dutch VAT registration is a separate service.
The licence choice
General or limited, with who registers, whose number is used and how far the representative is liable.
The licence request
Filed by the representative with the inspector, with your written authorisation (machtiging) (art. 33g(4) and (5) Wet OB).
The security
Sized from the Belastingdienst formula and posted in one of five accepted forms of zekerheid (security).
The article 23 licence
The vergunning artikel 23, requested in your name by a general representative, or a limited representative's own.
Each VAT period
Return, ICP declaration and import reverse charge, filed by the representative (Belastingdienst, Tax representative); see how to read and check a Dutch VAT number.
Changes and exit
The security moves with your volumes; after the licence ends, it is held 5 years from the end of that financial year.
Where our work stops
No general power of attorney, director, registered address or bank guarantee, and no promise of the inspector's decision. Payroll: the payroll services page.
When a fiscal representative is needed
"Foreign" means not established in the Netherlands, whatever the nationality; a goods depot is not an establishment. Mandatory cases rest on art. 33g(2) Wet OB.
- Often not needed
Selling only to Dutch-established businesses: the customer owes the VAT under the reverse charge (art. 12(3) Wet OB). Otherwise representation is optional.
- Mandatory: online sales from outside the EU
A non-EU business owing Dutch VAT on distance sales needs a general representative, unless it uses OSS or IOSS (Belastingdienst, Fiscaal vertegenwoordiger). Non-EU IOSS needs a Dutch-established intermediary.
- Mandatory: excise, mineral-oil and bulk goods
Excise goods or mineral oils at 0 percent VAT, bulk goods at 0 percent, or goods leaving an excise or VAT warehouse: general or limited.
- Needed for the reverse charge on import
A foreign company wanting the article 23 licence must engage a tax representative; it cannot apply itself.
General or limited licence
The choice decides whose number is used and how far the representative is liable.
General and limited licences compared, from the Belastingdienst's general licence and limited licence pages, checked on 4 October 2026.
| Point | General licence (algemene vergunning) | Limited licence (beperkte vergunning) |
|---|---|---|
| Scope | All taxable supplies of goods and services, intra-Community acquisitions and imports from outside the EU | Imports and the supplies that follow (distance sales excluded); excise, bulk and certain mineral-oil goods at 0 percent; goods released from an excise or VAT warehouse |
| Client registered with the Belastingdienst | Yes, required | No |
| Number of representatives | Never more than one | More than one allowed |
| Number used on returns and import declarations | The client's own Dutch VAT ID | The representative's sub-number (subnummer), plus its own VAT ID for ICP declarations |
| Client's authorisation | Sent with the licence request | Written, kept in the representative's records |
| Article 23 licence | Applied for by the representative in the client's name | One licence for all clients, on the sub-number |
| Representative's liability | Per calendar year, at most the security | The whole tax, interest and administrative penalties; the security may be used for any client |
How fiscal representation is arranged
Eight steps, with the Belastingdienst's timing where it publishes one.
Published Belastingdienst timeNo published time
- Need testYou and us: customers, goods flows, any Dutch establishmentBefore anything is filed
- Licence choiceGeneral or limitedNo official time
- Data and authorisationFrom you; for a general licence, VAT registration firstNo official time
- Licence requestFiled by the representativeAcknowledged within 10 working days; handled within 8 weeks
- Security postedSet by the Belastingdienst; the licence issues only once it standsNone published for a bank guarantee
- Article 23 requestThe representative applies; the inspector sets a start dateDecision within 8 weeks Runs after the licence, not alongside
- Each periodImport declarations, the VAT return and the ICP declarationA foreign company files within 2 months after the period
- Changes and exitIncreases apply at once, reductions after the naheffingstermijnSecurity held 5 years after the licence's final financial year
Need test
Your customers, goods flows and any Dutch establishment. Timing: before anything is filed.
Licence choice
General or limited, from the table above. Timing: no official time.
Data and authorisation
From you; for a general licence, VAT registration first, and a login (see eHerkenning). Timing: no official time.
Licence request
Filed by the representative; its own tax office, not the Department of International Issues (Kantoor Buitenland), then handles your VAT. Timing: acknowledged within 10 working days; handled within 8 weeks.
Security
Set by the Belastingdienst and posted; the licence issues only once it stands. Timing: none published for a bank guarantee.
Article 23 request
By form or letter with evidence of regular imports; the inspector sets a start date and assigns a VAT ID. Timing: decision within 8 weeks.
Each period
Import declarations with the number and documents; import VAT declared and deducted on the return, with the ICP declaration. Timing: a foreign company files within 2 months after the period.
Changes and exit
Security increases apply at once, reductions after the additional-assessment window. Timing: security held 5 years after the licence's final financial year.
Not sure whether a general or a limited licence fits your imports?
We set the two licences against your goods flows and customers before anything is filed.
The security and what the state charges
No fee is stated for either licence. The money a licence needs is the security, held against your VAT, not charged.
Security and state charges, from the Belastingdienst's Zekerheid en aansprakelijkheid (security and liability) and fiscal representation pages, checked on 4 October 2026.
| Item | What the Belastingdienst states | Source |
|---|---|---|
| Fee for the fiscal representative licence | No fee is stated on its fiscal representation pages | Belastingdienst, fiscal representation pages |
| Fee for the article 23 licence | No fee is stated | Belastingdienst, fiscal representation pages |
| Security base | The average monthly VAT on the transactions covered; exempt and 0 percent ones count; input VAT is ignored; the same goods are counted once | Belastingdienst, security and liability |
| Security amount | 5 percent of the base per licence; minimum EUR 5,000; maximum EUR 100,000 (category 1: bulk goods, semi-finished goods, production means) or EUR 500,000 (category 2: other goods and services); a mixed flow is sized as category 2; more at elevated fraud risk | Belastingdienst, security and liability |
| Accepted forms | Surety (borgstelling), bank guarantee from a financial institution the Belastingdienst accepts (bankgarantie), mortgage, pledge, cash deposit | Belastingdienst, security and liability |
| Return of the security | Not earlier than 5 years after the end of the financial year in which the licence ended; an increase applies at once, a reduction only after the additional-assessment window (naheffingstermijn) | Belastingdienst, security and liability |
Our arithmetic from the formula: a EUR 60,000 monthly VAT base gives EUR 3,000, below the floor, so EUR 5,000. Assessments in the window can be met from it.
Base: average monthly VAT on the covered transactions; exempt and 0 percent ones count; input VAT ignored; 5 percent per licence
- Is 5 percent of the average monthly VAT base below EUR 5,000?The security is EUR 5,000, the floorThe security is the 5 percent amount, up to the cap
- Only category 1 goods: bulk goods, semi-finished goods, production means?Capped at EUR 100,000Category 2, other goods and services, or a mixed flow: capped at EUR 500,000
- Elevated fraud risk?More can be requiredThe formula amount stands
Worked example: our arithmetic from the Belastingdienst formula
The article 23 licence
Without it, import VAT is paid to Customs (Douane) and deducted later (Belastingdienst, Vergunning artikel 23 aanvragen). With it, the VAT is declared and deducted on one return: a VAT deferment leaving nothing to pay where deduction is full.
- Import VAT levied from designated entrepreneurs, art. 23(1) Wet OB
- A foreign company cannot apply itself; its representative applies
- Conditions: establishment or representative, regular imports, clear records (art. 18(2) Uitvoeringsbeschikking omzetbelasting 1968)
- Covers all goods imported for the holder, or on its instruction
- Evidence: order confirmations, purchase invoices or import documents
- Annex A (bijlage A) goods are designated without a request
- No annual return; not under the KOR (art. 23(5) Wet OB)
- Rates 21, 9 or nil percent (art. 9 Wet OB): netherlands vat rate
Documents and data you will need
What the representative needs before the request goes in.
- A written authorisation (machtiging) naming the representative
- Company name, address, business and any EU VAT ID
- Start date, and nature and volume of transactions per year
- Expected monthly VAT on covered transactions, to size the security
- For article 23: kind, value, origin and frequency of imports
- For a general licence: your own Dutch VAT registration
- Identification of the company and its beneficial owners (Wwft)
- For each import: copy invoice, freight and loading papers
- Records showing the import VAT simply
Problems we solve
The rule behind five common questions.
- "Who pays if the VAT is not paid?"
Your company always stays liable. A general representative is liable up to the security per calendar year, a limited one in full, so the client funds or counter-guarantees the security.
- "Can we keep the small businesses scheme?"
Not with article 23: the licence is closed under the KOR, and a holder may not file yearly.
- "Our bookkeeper already files for us"
That is an authorised representative (gemachtigde): no licence, no reverse charge on import. Filing in that role sits with our tax consultant in the Netherlands service.
- "Why was the designation withdrawn?"
Misuse or breached conditions, including by the carrier; import papers without the number put it at risk. Cars, vans and motorcycles need six months of regular imports (art. 18a).
- "What if the company is established here?"
It then meets the article 23 condition itself (art. 18(2)(a)). A ready-made Dutch BV, taken over by notarial share transfer with our buyer-side help, brings what bookkeeping a Dutch BV has to keep.
Goods arriving before the licence is in place?
Until the licence and the security stand, import VAT is paid at Customs. We plan the sequence around your first shipments.
Why work with us
We test the need on your customers and goods flows, set out the licence choice with its liability, size the security before you approach your bank, and check the number and copy invoice travel with every import, alongside the representative's tax office, Customs and your forwarder.
Ilse Brouwer, tax, VAT and licensing lead, Amsterdam; Dutch, English and French.
Frequently Asked Questions
Do I have to appoint a fiscal representative at all?
Not always. The Belastingdienst says representation is optional in general and mandatory in some situations, such as distance sales from outside the EU without OSS or IOSS, and excise or bulk goods at 0 percent. A supplier whose customers are Dutch-established businesses is usually covered by the reverse charge of art. 12(3) Wet OB.
How big is the bank guarantee, and when do I get it back?
The Belastingdienst sets the security at 5 percent of the average monthly VAT on the covered transactions, per licence, with a minimum of EUR 5,000 and a maximum of EUR 100,000 (category 1) or EUR 500,000 (category 2). It is not returned earlier than 5 years after the end of the financial year in which the licence ended.
Who is liable if VAT goes unpaid: my company or the representative?
Your company always stays liable for its own tax obligations. A representative with a general licence is jointly liable, per calendar year, up to the security the inspector set; a representative with a limited licence is jointly liable for the whole amount of tax, interest and administrative penalties.
Can my company apply for the article 23 licence without a representative?
Not if it has no establishment in the Netherlands. The regulation requires residence, establishment, a permanent establishment or a fiscal representative there, and the Belastingdienst states that a foreign entrepreneur cannot apply for the Article 23 permit itself: its tax representative applies for it.
How long does it take to get the licence and the article 23 permit?
For the fiscal representative licence the Belastingdienst acknowledges a request within 10 working days and handles it within 8 weeks; the licence issues only after the security is in place. An article 23 request is decided within 8 weeks. These are service standards, not statutory terms, and the two run one after the other.
Is a bookkeeper who files my returns the same as a fiscal representative?
No. A bookkeeper or tax adviser who files for you is an authorised representative: no licence and no requirements apply. Only a tax representative, licensed by the inspector, can apply the reverse charge on import for a foreign company. Filing as an authorised representative is part of our tax advice service.
What is the difference between general and limited fiscal representation?
A general licence covers all taxable supplies, intra-Community acquisitions and imports; the client must be registered and may have only one general representative. A limited licence covers a set of transactions such as imports and the following supplies; the client need not register and may have several representatives, who file under their own sub-number.
What is article 23 in the Netherlands?
Article 23 of the Wet OB lets import VAT on goods for designated entrepreneurs be levied from them instead of at import. The tax falls due at import and is declared on the periodic return, where it is deducted as input tax, so nothing is paid in advance at Customs.
Can I claim back import VAT?
Without an article 23 licence the importer pays VAT to Customs on the import declaration and deducts it later on its return where it has a right of deduction. With the licence the VAT is declared and deducted on the same return, so per saldo no VAT is paid on the import.
What are the requirements for an article 23 licence?
Residence or establishment in the Netherlands or a fiscal representative there, regular imports (or occasional ones with a representative), and records that show the import VAT simply. The request comes with evidence such as order confirmations or import documents. A holder may not file yearly, and the licence is closed under the KOR.
Do I still need a Dutch VAT registration if I use a representative?
It depends on the licence. A client of a general fiscal representative must be registered with the Belastingdienst, and returns use the client's own Dutch VAT ID. A client of a limited representative need not register: the representative files under its own sub-number, and quotes it on the import declaration.
I sell online from outside the EU to Dutch consumers: do I need a general fiscal representative?
Yes, if the business owes Dutch VAT on distance sales and is established outside the EU, unless it declares the VAT through the Union scheme (OSS) or the Import scheme (IOSS). Registration for IOSS from outside the EU is possible only through an intermediary established in the Netherlands.
What must appear on my invoices and import declarations?
Where the tax is paid by a fiscal representative, the invoice carries the representative's VAT ID with its full name and address (art. 35a(1)(q) Wet OB). At import, the copy invoice and transport papers carry the VAT ID; a limited representative quotes its sub-number on the import declaration.
Which tax office handles my VAT once I have a representative?
The Netherlands Tax Administration is the Belastingdienst. Its Department of International Issues handles Dutch VAT for foreign entrepreneurs, except those with a tax representative: once one is appointed, the representative's own tax office deals with your VAT, from the licence request onwards.
Request a fiscal representation plan
Tell us your goods, your customers and your expected monthly VAT; we set out the licence, the security and the sequence. Pricing on request.