Amazon FBA and VAT in Spain
Spis treści
Amazon FBA (Fulfilment by Amazon) is a logistics model that allows sellers to scale without the burden of handling storage or shipping themselves. In short: you send your products to Amazon’s warehouses, and the platform takes care of the rest — from warehousing and order fulfilment to customer service and returns. For small businesses and emerging brands, it’s a huge advantage, offering seamless access to customers across Europe.
But anyone who’s ever dealt with the EU VAT system knows that convenience comes with a web of obligations, exceptions, and rules that can quickly become overwhelming.
So why is the Netherlands suddenly at the centre of so many FBA discussions? Because from June 25, 2025, Amazon is implementing a significant change to its Pan-European FBA (Pan-EU) programme. From that date, every seller participating in Pan-EU will be required to have active listings on Amazon.nl, the Dutch version of the marketplace.
For many businesses that have so far focused primarily on Germany, France or Spain, this represents a new compliance layer — one that demands a closer look at the Dutch VAT framework.
At first glance, this change might seem like a simple marketing move — just another market added to the list. But in practice, it carries much deeper implications. Even if your goods are not physically stored in the Netherlands, selling to Dutch customers brings your business into the Dutch VAT system for Amazon FBA, which means additional responsibilities: from registration and invoicing to filing and reporting sales correctly.
For entrepreneurs building their brands on Amazon, this is the perfect moment to get their tax affairs in order. The Dutch VAT system is, on one hand, transparent and efficient — but on the other, full of nuances that can determine whether your business runs smoothly or gets tangled in red tape.
This guide will take you through everything you need to know about how Amazon FBA VAT works in the Netherlands — from the basics and registration requirements to practical strategies for tax optimisation. You’ll learn when VAT registration in the Netherlands is mandatory, when it can be avoided, and how to benefit from simplifications such as the OSS (One Stop Shop) system or Article 23, which allows you to defer VAT payment on imports.
We’ll also highlight the most common mistakes sellers make when dealing with the Dutch tax authorities — and how to avoid them before they turn into costly financial setbacks.
In short — if you run an Amazon store and plan to expand your European presence, you need to understand how VAT works in the Netherlands in the context of Amazon FBA. This article will walk you through all the key points step by step, in a clear and practical way — without jargon, without shortcuts, but with a genuine understanding of how this system impacts your business and your bottom line.
You’ll learn when to register, how to avoid common pitfalls, and how to optimise your VAT reporting so that your company stays compliant — and financially efficient. This isn’t just theory — it’s a practical guide to European e-commerce realities, helping you sell more confidently, sustainably, and with full control over your tax obligations.
Do You Need VAT Registration in the Netherlands as an Amazon FBA Seller?
If you operate under the Amazon FBA model, the question of VAT registration in the Netherlands essentially comes down to two key factors: where your goods are physically stored, and how much you sell to Dutch customers. In practice, these two criteria determine whether a Dutch VAT number (NL VAT) is mandatory for your business — or whether you can continue selling without it.
The topic of Amazon FBA and Dutch VAT sits right at the crossroads between logistics and taxation — and it’s precisely there that most misunderstandings arise.
When VAT Registration Is Required
The first rule is straightforward: if your goods are physically stored in the Netherlands, you are required to register for VAT there. For foreign businesses, the registration threshold is effectively zero, meaning that simply storing goods or selling from Dutch territory automatically triggers the VAT registration obligation.
For businesses based in the Netherlands, a local annual turnover threshold of €20,000 applies, but this does not extend to non-Dutch sellers. In short: if Amazon stores your stock in a Dutch warehouse, you must register for VAT in the Netherlands, regardless of your turnover.
The second factor relates to distance sales to private customers within the EU. Since 1 July 2021, national thresholds were replaced with a single EU-wide limit of €10,000 per year. Once your cross-border B2C sales exceed that amount, you must apply the VAT rate of your customer’s country of residence.
You can handle this in one of two ways:
– by registering locally for VAT in that country (for instance, in the Netherlands),
– or by using the OSS (One Stop Shop) system in the country where your business is established.
OSS was introduced to help sellers avoid multiple VAT registrations across different EU states. It allows you to report and pay VAT on all B2C EU sales in one quarterly return. As long as your goods are not physically stored in the Netherlands and you don’t operate a local establishment there, you can rely on OSS and skip local VAT registration.
However, it’s important to remember that OSS does not cover situations where your goods are physically stored in the Netherlands. If Amazon places your inventory in a Dutch fulfilment centre, you’ll need a local VAT number — even if the total value of your sales remains low. That’s why it’s crucial to know where Amazon actually stores your stock, especially if you’re part of the Pan-European FBA programme, where Amazon manages logistics across multiple EU countries on your behalf.
If you operate from a single country — for example, from Germany — and only ship to the Netherlands occasionally, while your total EU B2C sales stay below the €10,000 threshold, you’re not yet required to register for Dutch VAT. But as your sales grow or your logistics become more automated through FBA, you should prepare for the fact that the obligation will likely arise sooner rather than later.
Amazon FBA and Pan-EU: How the System Works in Practice
To fully understand when VAT registration in the Netherlands becomes necessary, it’s worth looking at how Amazon’s logistics network operates. The company offers three main fulfilment models: local FBA, Pan-European FBA (Pan-EU), and EFN (European Fulfilment Network). Each comes with different tax implications.
Under local FBA, goods are stored in one country — for example, in Germany — and shipped directly to customers across Europe. In this scenario, you don’t need a Dutch VAT number unless your EU-wide sales to private customers exceed €10,000. Once you pass that threshold, you must apply the VAT rates of your customers’ countries, which you can easily manage through OSS without the need for local registration.
The Pan-European FBA model, however, works differently. In this system, Amazon can move your inventory between its warehouses in different EU countries to optimise delivery times and logistics. Each such transfer of goods is treated as an intra-EU movement of goods, which creates a VAT registration requirement in the destination country.
That’s why Pan-EU FBA sellers typically hold several VAT numbers — for example, in Germany, France, Spain, Italy, and soon, in the Netherlands.
From 25 June 2025, Amazon will introduce a new rule within the Pan-EU programme: every new product listing (ASIN) must also be active on Amazon.nl. This means that all Pan-EU sellers will need to include the Netherlands among their active sales markets.
While this doesn’t automatically mean that your goods will be stored in Dutch warehouses from day one, it significantly increases the likelihood that they will be in the near future. Once that happens, Dutch VAT registration becomes mandatory.
By contrast, the EFN (European Fulfilment Network) model allows Amazon to ship products from a single country to multiple EU markets without storing them abroad. If you operate under EFN and ship from Germany to Dutch customers, you do not need local registration as long as your total EU B2C sales stay under €10,000 — or as long as you use OSS for your reporting. Once that threshold is exceeded, you must charge Dutch VAT, either through OSS or via direct registration in the Netherlands.
It’s also worth noting that Amazon continues to expand its logistics infrastructure in the Netherlands. The official sell.amazon.nl website already highlights local fulfilment options, signalling that storage in Dutch warehouses is becoming more common.
For European sellers, this is a good time to prepare for potential Dutch VAT registration and familiarise themselves with how the local tax system works — before these changes take full effect.
If you operate under a local FBA model with your goods stored in one country (for instance, Germany) and your Dutch sales remain modest, you can continue using the OSS system and avoid local registration for now.
However, once your products are stored in Dutch warehouses or your total EU B2C sales exceed €10,000, a Dutch VAT number becomes mandatory.
Given the ongoing evolution of the Pan-European FBA programme and the growing importance of the Dutch market, it’s increasingly a matter of “when” rather than “if.”
Amazon Fulfilment Centres in the Netherlands – Current Status and Strategic Importance
List of Active Sites (AMS2–AMS7)
In logistics discussions, you’ll often see internal Amazon codes such as AMS2, AMS3, AMS4, AMS5, or AMS7. These aren’t official “marketing names” of FBA warehouses, but rather operational identifiers used internally by Amazon. The presence of such a code doesn’t necessarily indicate a fulfilment centre. Some of these facilities are sorting hubs or last-mile delivery stations, while only certain locations serve as full fulfilment centres where third-party sellers’ inventory can be stored long-term.
It’s also worth noting that not all Dutch facilities follow the “AMSx” naming scheme — Amazon uses various formats, including four-letter codes like VERI or mixed alphanumeric identifiers. So, the label alone doesn’t confirm whether a location is part of the FBA network.
From a tax perspective, what matters is not the code but whether your SKUs are physically stored in a Dutch fulfilment centre. Simply having an Amazon site with an “AMS” prefix does not trigger a VAT obligation. The requirement arises only once your inventory is actually located in the Netherlands and orders begin shipping from there to customers.
That’s why regularly monitoring your inventory movement reports in Seller Central is crucial. If you notice a stock transfer to a Dutch location in your reports, that’s your signal: you’ve effectively entered the Amazon FBA VAT Netherlands regime, meaning you’ll need a Dutch VAT number and must follow local invoicing and reporting rules.
It’s also important to recognise that the Netherlands already hosts operational fulfilment centres, not just sorting and delivery stations. In other words, the possibility of your stock being stored in the Netherlands is no longer hypothetical — though not every seller will experience it right away. This is why the only reliable indicator is your account data, not the building code.
Potential Expansion and the Future of the FBA Network in the Netherlands
The Netherlands is gaining strategic importance within Amazon’s European operations for two main reasons.
First, the Amazon.nl marketplace continues to grow rapidly, and faster delivery has become a key competitive advantage — a trend that naturally encourages Amazon to move inventory closer to Dutch customers.
Second, from 25 June 2025, sellers participating in the Pan-European FBA (Pan-EU) programme must have active listings on Amazon.nl whenever they add new ASINs. While this is a listing requirement rather than an immediate guarantee of storage in the Netherlands, it will inevitably increase the Dutch market’s role in your overall sales and raise the likelihood that some of your stock will eventually be stored locally.
Once that happens, your VAT obligations change instantly. The OSS system works perfectly for cross-border B2C sales once you exceed the EU-wide €10,000 threshold — but it does not replace local registration when goods are physically stored in a particular country.
In practice, this creates a simple decision tree:
– If you ship orders to the Netherlands from another EU country and your goods aren’t stored there, you can handle Dutch VAT through OSS without obtaining an NL VAT number.
– If Amazon stores your SKUs in a Dutch fulfilment centre, you move into the full Amazon FBA VAT Netherlands framework, which means local VAT registration, local returns, and invoicing according to Dutch rates of 21% and 9%.
The most sensible strategy for the coming months is to combine logistics monitoring with solid tax discipline. Regularly check your inventory movement reports so you don’t miss the moment your products appear in a Dutch facility. At the same time, keep track of your EU-wide €10,000 threshold, since that determines whether your B2C sales to Dutch customers should already be reported via OSS before local storage becomes relevant.
If you plan to import goods through the Netherlands or set up a Dutch fulfilment hub, consider using the Article 23 import VAT deferment scheme, which helps stabilise cash flow once your volume begins to grow.
The Long-Term Outlook
It’s realistic to assume that Amazon’s physical presence in the Netherlands will continue to expand. The more significant Amazon.nl becomes in your sales mix — and the more your business depends on fast delivery — the more likely it is that your goods will be stored locally.
The best approach is to prepare early. Your “ready-to-go” checklist should include:
a Dutch VAT number, knowledge of local VAT rates and invoicing rules, a clear filing calendar, and a returns management plan for orders shipped from the Netherlands.
That way, when Amazon relocates your stock into Dutch warehouses, you’ll already be compliant — and your growth won’t be disrupted by last-minute tax surprises.
VAT Rates in the Netherlands – What You Need to Know
The Dutch VAT system is known for being clear, stable, and well-structured, but understanding it properly is one of the key elements of successfully selling on Amazon.nl.
When it comes to Amazon FBA VAT Netherlands, applying the correct VAT rate has a direct impact on your profit margins, compliance, and credibility — both with customers and with the Dutch Tax and Customs Administration (Belastingdienst).
Standard and Reduced Rates
The Netherlands applies three main VAT rates: 21% (standard), 9% (reduced), and 0% (zero-rated).
The 21% standard rate covers most goods and services available on Amazon.nl. This includes clothing (including children’s apparel), electronics, cosmetics, home accessories, fitness equipment, office supplies, and most products that don’t fall into specific preferential categories. It’s the default rate applied by the vast majority of Amazon FBA sellers operating in the Dutch market.
The 9% reduced rate applies to goods and services considered by the Dutch government to be essential or of social importance. These include:
– food and non-alcoholic beverages,
– medicinal products and approved pharmaceuticals,
– printed books, e-books, and other digital publications (since 1 January 2020),
– hairdressing services,
– bicycle repairs,
– clothing repairs and alterations (but not the sale of clothes, even children’s garments).
It’s worth emphasising this point: the sale of clothing, including children’s clothing, is subject to 21% VAT in the Netherlands, even though some other EU countries apply reduced rates in this category. This is a common mistake among sellers who operate across multiple European markets and assume VAT preferences are harmonised everywhere — they are not.
The 0% rate applies to:
– exports of goods outside the European Union, and
– intra-Community supplies (ICS), i.e. B2B sales to VAT-registered businesses in another EU country.
However, to apply the 0% rate for intra-EU sales, you must meet strict conditions. You need to:
– verify your customer’s VAT number in the VIES system, and
– keep documentary evidence proving the physical movement of goods outside the Netherlands.
You must also report such transactions in your ICP (intra-Community summary declaration).
If these conditions aren’t met, the Belastingdienst may challenge the transaction and reclassify it under the 21% rate, requiring you to pay the difference plus potential penalties.
How VAT Rates Apply to Amazon.nl Sales
When selling on Amazon.nl, correctly assigning the VAT rate to your products is your responsibility as the seller, not Amazon’s.
While Amazon allows you to configure VAT rates in Seller Central, it does not verify their accuracy. Therefore, before launching products in the Dutch market via FBA, it’s essential to check which rate applies to each category.
Importantly, VAT classification in the Netherlands is not determined by customs codes (CN/TARIC) — though those can help you orient yourself. The final decision is based on Dutch tax catalogues published by the Belastingdienst, which clearly specify which goods and services fall under the 9% or 0% rates. These official lists are the only authoritative reference for sellers.
If your product range includes multiple categories — for example, fitness equipment, books, and food supplements — you may need to apply different VAT rates within the same Amazon account. In such cases, it’s crucial to assign the correct rate to each SKU and ensure your invoicing reflects this accurately.
Amazon automatically pulls VAT rate data into invoices issued to customers, meaning that any configuration error can lead to incorrect VAT reporting — and potential corrections later on.
For B2C sales to the Netherlands through the OSS (One Stop Shop) scheme, the same rule applies: VAT rates must correspond to the legislation of the country of consumption.
The OSS system simplifies VAT declarations by allowing you to report through the country where you’re registered, but it doesn’t relieve you of the obligation to apply the correct local VAT rate for each product.
For example:
– if you sell e-books to customers in Poland, you apply 23%,
– to customers in the Netherlands, you apply 9%,
– and to customers in Germany, 7%.
These differences clearly show how important it is to account for local VAT regulations when expanding across Europe.
Compliance and Audit Considerations
In the context of Amazon FBA VAT Netherlands, it’s also worth remembering that the Belastingdienst is highly meticulous when auditing e-commerce businesses.
If you apply the 9% reduced rate, you must be able to prove that your product qualifies for it under Dutch tax law.
If there’s any doubt, the authority may demand a correction and additional VAT at the 21% rate.
For that reason, it’s generally safer to apply the standard rate when you’re uncertain about classification — until you can verify your product’s eligibility for the reduced rate.
Finally, it’s worth noting that the Dutch government plans to review its VAT rate structure in 2026, potentially removing some preferential categories, particularly in hospitality and cultural services. While these changes won’t directly affect most Amazon sellers, it’s still wise to monitor official announcements from the Belastingdienst, as any reform could have ripple effects on less obvious product categories.
The Three Golden Rules for Amazon FBA Sellers
For anyone selling on Amazon.nl, success starts with mastering VAT compliance. Keep in mind three essential principles:
- Know which VAT rate applies to each of your products.
- Apply it consistently across your entire Amazon catalogue.
- Keep thorough documentation to justify any use of reduced or zero rates.
Following these rules minimises the risk of VAT errors, audits, or costly corrections — and ensures your Amazon.nl business operates fully in line with Dutch tax law.
VAT Registration in the Netherlands – Step by Step
For many sellers operating under the Amazon FBA VAT Netherlands model, VAT registration marks their first real interaction with the Dutch tax system. At first glance, the process might seem formal and bureaucratic — but in reality, it’s straightforward and logical, as long as you understand how it works.
The procedure varies slightly depending on whether your company is based inside or outside the European Union, but the goal remains the same: to enable you to legally handle VAT on sales and imports within the Netherlands.
VAT Registration for EU-Based Businesses
If your company is registered in an EU member state, you can register for Dutch VAT directly — there’s no need to appoint a fiscal representative.
The Dutch Tax and Customs Administration (Belastingdienst) handles VAT matters for foreign entrepreneurs through a dedicated department located in Heerlen. This is where all applications from EU-based businesses are processed.
Registration is done by completing the form “Aanvraag registratie btw-nummer buitenlandse ondernemers binnen EU” (Application for VAT Number for Foreign Entrepreneurs within the EU), available on the Belastingdienst website under the section for foreign businesses.
The form should be printed, signed, and sent by post to Belastingdienst/kantoor Buitenland, Heerlen, as electronic submissions are not always accepted. Processing usually takes two to four weeks, with most businesses receiving their VAT number in about three weeks.
During the review process, Belastingdienst may request supporting documents proving your business activity, such as sales invoices, your Amazon seller agreement, a trade register extract, or proof of your VAT registration in your home country. Typically, you’ll also be asked to provide an ID copy of the owner or director and a bank account number for tax payments.
Once your application is approved, you’ll receive a VAT number in the format NL123456789B01 — where the first nine digits identify the business, “B” indicates VAT registration, and the final two digits refer to the branch or entity. This number must appear on all invoices, accounting records, and communications with Amazon.
One of the main advantages for EU sellers is that you don’t need to register with the Dutch Chamber of Commerce (KVK). As long as you operate solely through e-commerce and have no physical establishment or staff in the Netherlands, a KVK entry isn’t required.
After registration, the business is automatically assigned a VAT filing schedule. Most sellers file quarterly returns, though high-volume sellers may be moved to monthly filing — the final decision rests with Belastingdienst.
It’s also worth noting that EU-based companies can apply for Article 23 authorisation, which allows deferral of VAT payments on imports. This can significantly improve cash flow by avoiding upfront VAT at customs. Belastingdienst may, however, request additional financial guarantees or security, particularly from newer companies without a track record of VAT compliance.
VAT Registration for Non-EU Businesses
For companies based outside the European Union, the rules are more stringent. Dutch law requires that any non-EU business registering for VAT must appoint a fiscal representative.
A fiscal representative (fiscaal vertegenwoordiger) is a Dutch-registered company or tax adviser authorised by Belastingdienst to act on your behalf. They’re legally responsible for ensuring your VAT compliance and communication with the tax office.
There are two types of representation:
- General Fiscal Representation – full representation covering VAT declarations, Intrastat reports, and all correspondence with Belastingdienst.
- Limited Fiscal Representation – restricted to import operations, typically used in the FBA model when goods are imported into the EU through the Netherlands.
Hiring a fiscal representative typically costs several hundred to a few thousand euros per year, depending on the level of service. For Amazon FBA sellers, however, this is standard practice — and often a relief, since the representative manages all the formalities and communication with the authorities.
Non-EU businesses also need a fiscal representative if they want to benefit from the Article 23 import VAT deferment scheme. Under Article 23, VAT on imports doesn’t need to be paid at customs; instead, it’s declared and reclaimed in the same VAT return — effectively resulting in no cash outflow at the time of import.
In VAT returns, this appears as output tax (box 4) and input tax (box 5b), which cancel each other out. This allows goods to be released into circulation without tying up capital in advance VAT payments.
To obtain Article 23 authorisation, you must already have an active Dutch VAT number and submit an application for an “artikel 23 vergunning” to Belastingdienst.
Non-EU companies must also provide a bank guarantee or other form of financial security, assuring the tax authority of their reliability and compliance.
Timeline, Procedure, and Practical Details
The full registration process generally takes two to four weeks. For non-EU companies, it may take slightly longer if the authorities request extra documentation.
Once registration is complete, your VAT number and confirmation letter are sent by post — there’s no digital certificate. VAT returns are then submitted online through the Belastingdienst portal, and payments are made via bank transfer to the account specified in your registration letter.
Most Amazon FBA sellers file quarterly VAT returns, though those with higher turnover may be assigned a monthly schedule.
Ultimately, VAT registration in the Netherlands is not just a legal obligation — it’s a gateway to operating efficiently within Amazon’s European logistics network.
For EU-based companies, it’s a straightforward procedure that grants quick access to one of the fastest-growing Amazon markets in Europe.
For non-EU sellers, it requires working with a fiscal representative, but also opens the door to valuable tools like Article 23, which can greatly enhance cash flow and profitability.
In both cases, the key takeaway is simple: the earlier you complete your registration, the smoother your entry into Amazon.nl will be — avoiding shipment delays, account holds, and unnecessary interruptions in your sales.
The VAT Number in the Netherlands and Why It Matters
In the context of Amazon FBA VAT Netherlands, a VAT number is far more than an administrative formality. It is the foundation of compliant operations and the clearest proof that a seller conducts business in full accordance with both EU legislation and the domestic rules of the Dutch Tax and Customs Administration, known as Belastingdienst. For anyone selling through Amazon.nl or storing goods in Dutch fulfilment centres, possessing and correctly using a valid Dutch VAT number is an absolute prerequisite for lawful and transparent trading.
VAT Number Format
Every Dutch VAT number follows the same structure: the prefix NL, nine identifying digits, the letter B, and a two-digit suffix, for example NL123456789B01. The first nine digits represent the company’s individual identification code. For Dutch-registered entities, this may be linked to a national business or citizen identifier such as the BSN or RSIN, whereas for foreign sellers the sequence is generated directly by Belastingdienst. The letter B stands for omzetbelasting, or value-added tax, and the final two digits form what is known as the branch identifier, or filiaalnummer. In practice, most foreign businesses are assigned the suffix B01, which designates their first and only registration in the Dutch VAT system. This format is consistent for both domestic and foreign companies, ensuring the same recognition and traceability across all EU jurisdictions.
BTW-identificatienummer and OB-nummer
Since 2020 the Netherlands has used two separate identifiers related to VAT. The public-facing one, the BTW-identificatienummer, is the number beginning with NL. It appears on invoices, in the OSS reporting system, in EU transaction summaries, and in Amazon Seller Central. It is the number that identifies the seller to customers and commercial partners. Alongside it exists the OB-nummer, or Omzetbelastingnummer, which is used solely for administrative communication with Belastingdienst, such as submitting returns, filing amendments, or handling correspondence. For most foreign businesses both numbers are identical, but for some locally registered companies they may differ. The essential rule is that the BTW-identificatienummer, the one starting with NL, must always be used on invoices and within Seller Central.
Practical Use of the VAT Number
The VAT number must appear on every sales invoice, regardless of whether the transaction involves a business or a consumer. In sales to private customers, displaying the seller’s VAT number is sufficient. In business-to-business transactions within the European Union, the seller’s and buyer’s VAT numbers must both be shown, particularly when the sale qualifies as an intra-Community supply subject to the 0 percent rate. Failure to include these details can result in an invoice being rejected or a tax return being challenged by Belastingdienst.
In cross-border commerce, the VAT number also serves as a verification tool that enables the application of the 0 percent rate for exports outside the European Union and ensures the proper accounting of intra-EU stock transfers. For Amazon FBA sellers who move inventory between warehouses—for example, from Germany to the Netherlands—the Dutch VAT number is what allows these movements to be recorded as intra-Community transactions rather than domestic sales. Although not required by law, Amazon and its logistics partners generally recommend including the VAT number in transport and stock movement documentation, as doing so helps maintain clear evidence of goods flows for OSS reporting purposes.
The VAT Number in Amazon Seller Central
Within Amazon’s ecosystem, the VAT number is one of the most crucial components of a seller’s account configuration. Amazon requires every seller to maintain an active VAT registration in each country where goods are physically stored or where the seller is obliged to account for VAT locally. Sellers who operate exclusively through the OSS scheme and ship goods to Dutch customers from another EU country do not need a Dutch VAT number, provided that no inventory is stored on Dutch territory.
In Seller Central, the VAT number is entered under “Tax Settings.” The platform uses this number automatically for invoicing, VAT reporting, and the calculation of tax on B2C sales. It is essential that the company details—its legal name, address, and country of registration—match exactly the data provided to Belastingdienst, since inconsistencies can cause reporting errors or delays in OSS submissions. A missing or incorrect VAT number can lead to restricted account functionality, withheld payments, or even the suspension of listings on Amazon.nl. Amazon has become increasingly strict about tax compliance, and in both the Pan-European FBA and EFN programmes, an active VAT number in each storage country is an entry requirement.
Deactivation and Maintaining an Active Number
Belastingdienst may deactivate a VAT number if a business remains inactive or fails to submit returns for a prolonged period, typically around twelve months. To prevent this, sellers who are temporarily not trading are advised to submit zero returns. Maintaining an active VAT number avoids the inconvenience of re-registration, which can take several weeks, and ensures the ability to resume sales instantly, move inventory within the FBA network, or apply Article 23 import VAT deferral without additional administrative steps.
The Strategic Role of the VAT Number in FBA
In the Amazon FBA VAT Netherlands framework, the VAT number performs several roles simultaneously. It is evidence of legal registration, a reporting mechanism, an identifier in OSS filings, and a marker of trust within the Amazon ecosystem. Without it, participation in programmes such as Pan-EU FBA is impossible. An active VAT number allows a seller to issue invoices that comply with Dutch law, to apply the 0 percent rate on intra-EU supplies and exports, to reclaim input VAT incurred in the Netherlands, and to remain fully aligned with EU VAT regulations. In essence, it is the passport to operating professionally on Amazon.nl—a confirmation that the business is transparent, compliant, and audit-ready.
Article 23 – Import VAT Deferral
For Amazon FBA sellers importing goods from outside the European Union, the most challenging moment in the tax process is often customs clearance. Under standard procedures, import VAT—usually 21 percent—must be paid immediately when goods enter the EU, long before they reach the warehouse or generate revenue. For fast-moving e-commerce operations, this upfront payment ties up valuable working capital. The Dutch tax system addresses this with the Article 23 permit, known in Dutch as the artikel 23 vergunning, which allows businesses to defer import VAT payment.
How Article 23 Works
Article 23 of the Dutch VAT Act (Wet op de Omzetbelasting 1968) authorises companies to declare import VAT directly in their periodic VAT return instead of paying it at customs. The importer reports the tax as output VAT in the relevant field of the return and deducts the same amount as input VAT in the same filing period. The outcome is purely accounting-based: the VAT is recorded for transparency but no actual payment occurs. The mechanism does not eliminate the tax—it simply postpones the payment, providing the importer with immediate financial flexibility. Article 23 applies only when goods are cleared in the Netherlands; it cannot be used for transit shipments or imports processed through other EU countries.
Eligibility and Application
The Article 23 permit is available to both Dutch and foreign businesses that hold an active Dutch VAT number and conduct import operations in the Netherlands. EU-based sellers may apply directly to the Belastingdienst office in Heerlen, which handles foreign taxpayers. The tax authority assesses each application individually, taking into account the company’s tax history, financial stability, and the nature of its business. Generally, EU businesses are not required to appoint a fiscal representative, although Belastingdienst may request one if the company has no fixed establishment in the Netherlands. In some cases, applicants must provide financial security, usually a bank guarantee ranging from five to twenty-five thousand euros, depending on the import volume.
Companies established outside the EU can benefit from Article 23 only through a fiscal representative authorised by Belastingdienst. This requirement, set out in Article 33 of the same act, ensures that the Dutch tax authorities have a responsible intermediary within the country. The representative assumes liability for the accuracy of the importer’s VAT returns and compliance with the deferral mechanism. In practice, non-EU sellers often choose limited fiscal representation, which restricts the representative’s role to import activities but allows full use of the Article 23 system with minimal administrative complexity.
Financial and Operational Advantages
The principal benefit of Article 23 is its effect on liquidity. Under standard procedures, businesses must pay import VAT upfront and reclaim it weeks later through a VAT return, temporarily immobilising large sums of money. With Article 23 in place, the same amount is declared and deducted in a single return, meaning no cash leaves the business at any stage. The result is improved cash flow and the freedom to reinvest capital immediately in new inventory, advertising, or market expansion. This difference between dormant and active capital explains why the Article 23 scheme is so widely used among Amazon FBA sellers importing from Asia.
There is also a logistical advantage: goods cleared under Article 23 are released immediately without waiting for VAT payment, which shortens customs procedures and prevents delays related to payment issues. From an accounting perspective, companies using Article 23 often submit monthly VAT returns rather than quarterly ones, giving them more granular control over import VAT and tax flows. Belastingdienst determines the reporting frequency when granting the permit, based on the company’s size and reliability. For FBA sellers, Article 23 also simplifies intra-EU logistics, since goods imported directly into the Netherlands can later be distributed across the Pan-EU network while the import VAT remains deferred.
Article 23 as a Strategic Tax Instrument
Article 23 is not a tax relief but an administrative facility that can produce substantial financial and operational benefits when used correctly. For EU-based Amazon sellers, obtaining a Dutch VAT registration specifically to access Article 23 can be a strategic move, particularly when expanding through the Pan-European FBA programme. For non-EU businesses, it is often the only viable method to import goods into the EU without an immediate VAT outlay. The permit enhances liquidity, accelerates logistics, and simplifies reporting—three elements that are central to success in the fast-paced world of Amazon FBA. In that sense, Article 23 is one of the most valuable tools offered by the Dutch tax system for any seller building a scalable European operation.
VAT Compliance Obligations in the Netherlands
Once your company is registered for VAT in the Netherlands and you begin selling through the Amazon FBA system, you must follow specific tax compliance rules. The Dutch VAT framework is transparent and well-organised, but it demands precision, punctuality, and awareness of a few procedural nuances that may differ from those in other EU countries. Among these are the so-called “24th-day rule” and the strict quarterly deadlines that form the backbone of the Dutch reporting calendar under the supervision of Belastingdienst, the Dutch Tax and Customs Administration.
Filing Frequency and Deadlines
Most businesses in the Netherlands file their VAT returns quarterly. This means they submit returns four times a year, each covering a standard calendar quarter: January to March, April to June, July to September, and October to December. The return must be filed by the last day of the month following the quarter’s end, and the payment of VAT must be made on the same day. For example, the return and payment for the first quarter are due by 30 April, for the second quarter by 31 July, for the third by 31 October, and for the fourth by 31 January of the following year.
Some companies are required to file monthly VAT returns instead. This typically applies to businesses with high turnover, those generating substantial amounts of VAT payable, or companies using the Article 23 import VAT deferral mechanism. More frequent reporting allows Belastingdienst to monitor cash flows in real time and ensure that import and VAT documentation remain fully aligned.
For sellers using the One Stop Shop (OSS) system, the principle is slightly different. OSS returns are filed in the seller’s country of identification — for example, where their business is registered — and also quarterly. However, OSS covers only cross-border B2C sales within the European Union, not domestic transactions. Therefore, if your goods are stored in a Dutch Amazon FBA warehouse, you must still file local Dutch VAT returns, even if you simultaneously report your EU cross-border sales through OSS.
It is important to note that all VAT returns in the Netherlands must be submitted electronically through the Mijn Belastingdienst Zakelijk portal. Paper submissions have not been accepted since 2019.
The “24th-Day Rule”
One of the lesser-known but crucial aspects of the Dutch VAT system is the “24th-day rule” (regel van de 24ste). According to this rule, a VAT return can only be submitted from the 24th day of the month following the reporting period. For example, a VAT return for the first quarter (January to March) can be filed only after 24 April.
If a return is submitted earlier, the Belastingdienst system will automatically reject it. The reason for this restriction is technical: it allows the authority to synchronise data from various sources, such as Intrastat filings, customs import records, and OSS declarations. This ensures that all intra-EU transaction data are harmonised and that tax flows across the European Union can be analysed accurately.
It is worth noting that the 24th-day rule applies only to the submission of the VAT return, not to the payment. Businesses may pay their VAT earlier if they already know the amount due. In practice, many Amazon sellers prepare their VAT return in advance but send it only after the 24th to avoid technical rejection or delays in processing.
Penalties for Late Filing or Errors
The Dutch tax authority is known for being pragmatic but also firm in enforcing compliance. Any delay in filing or payment is recorded, and repeated infractions can lead to financial penalties. The process is progressive. If you miss a filing deadline, Belastingdienst will first send a herinnering, or reminder. If there is no response, you will receive an aanmaning, a formal notice to comply. Continued inaction can lead to a boete, or financial penalty.
The fine for late filing usually ranges from €65 to €1,320, depending on whether the delay was a one-off or a recurring issue. If VAT is paid late, interest on arrears (invorderingsrente) is charged, currently set at 4% per annum in 2025. Interest is calculated from the day after the payment deadline until the day the liability is settled.
If an error appears in a VAT return, the taxpayer has the right to correct it voluntarily by submitting a supplementary return (suppletieaangifte). Corrections can be made within five years of the end of the fiscal year concerned, in accordance with Article 15 of the Uitvoeringsbeschikking OB 1968. Minor discrepancies — typically those below €1,000 — can be corrected directly in the next regular VAT return. For larger adjustments, a separate correction form must be submitted.
Voluntary corrections do not trigger penalties, provided that Belastingdienst has not already initiated an audit or investigation for that period. However, if an error is discovered by the tax office during an inspection, penalties may apply. In cases of proven intent or gross negligence, fines can reach up to 100% of the underpaid VAT.
For Amazon FBA sellers, maintaining well-organised documentation is essential. Amazon provides detailed VAT Transaction Reports and the VAT Calculation Service, which contain the data required for VAT filings. Nevertheless, the ultimate responsibility for accurate reporting rests entirely with the seller.
Maintaining Compliance and Reputation
The Dutch VAT system rewards consistency and transparency. Returns must be filed quarterly or monthly, submitted no earlier than the 24th day after the reporting period, and always electronically through Mijn Belastingdienst Zakelijk. Belastingdienst generally follows a measured approach: it sends reminders and formal notices before imposing fines, but persistent delays or repeated errors will result in sanctions. Minor mistakes, on the other hand, can easily be rectified through voluntary corrections.
For Amazon FBA businesses, punctual VAT filings are not merely a legal formality — they are a matter of business credibility. Timely submissions, accurate reporting, and clear communication with tax authorities demonstrate professionalism and reliability. In the highly competitive world of cross-border e-commerce, that reputation is as valuable as the sales themselves.
Invoicing in the Netherlands – Requirements and Common Mistakes
Issuing invoices in the Netherlands is not merely a bureaucratic formality; it is the very foundation of the VAT system. Under the Dutch VAT Act (Wet op de Omzetbelasting 1968), an invoice constitutes the primary proof that a taxable transaction has taken place and serves as the key document supporting every VAT return. It is designed to confirm the authenticity of a sale, enable the verification of tax obligations, and protect both the seller and the buyer. For businesses operating within the framework of Amazon FBA VAT Netherlands, its importance is even greater. Errors in invoicing can lead not only to penalties from Belastingdienst but also to account warnings or listing suspensions within Amazon Seller Central.
Mandatory Elements of an Invoice
Dutch VAT law sets out in precise terms what information an invoice must contain in order to be valid. Every invoice must show the seller’s full legal name and registered address, exactly as recorded with Belastingdienst, together with the VAT identification number in the format NL123456789B01. For intra-EU B2B transactions, the customer’s VAT number must also be stated. Each invoice must include the date of issue, a unique invoice number, and, where different, the date on which the goods were supplied or the service performed.
The description of the goods or services must be sufficiently detailed to allow the transaction to be clearly identified. It should specify not only the name of the item or service but also the quantity and the unit of measure, ensuring that the invoice can be directly matched to the actual delivery. Belastingdienst pays particular attention to this requirement, as overly generic descriptions such as “product” or “item” are not acceptable in VAT recordkeeping.
The invoice must state the net amount, the applicable VAT rate — whether 21%, 9%, or 0% — and the corresponding tax value for each line item. In cases where the 0% VAT rate applies, the invoice should include the annotation “Intra-Community supply – Art. 138 Directive 2006/112/EC.” When the reverse charge mechanism applies, it must contain the phrase “btw verlegd” or its English equivalent, “VAT reverse charge.”
Invoices must also be issued in a way that guarantees authenticity, integrity, and legibility. This means that electronic invoices are fully valid, provided these three conditions are met. A physical signature is not required in the Netherlands.
Invoice numbering must follow a logical and consistent sequence. There is no obligation to use a simple 1-2-3 order, but each number must be unique and traceable within the chronological series. Separate numbering series may be used for different sales channels, as long as traceability and integrity are maintained across all records.
If you use Amazon’s VAT Calculation Service (VCS), invoices are technically generated on your behalf, but you remain the formal issuer. This means that all legal responsibility for the accuracy of the data — including VAT rates, tax numbers, and product descriptions — lies entirely with you.
Simplified Invoices – When They Are and Aren’t Allowed
Dutch tax law allows for the use of simplified invoices (vereenvoudigde facturen) in certain limited cases. These documents contain fewer details than a standard invoice and can only be used when the total value of the transaction does not exceed €100 including VAT, or the equivalent amount in another currency. Simplified invoices may also be used in low-value retail sales where customer data is not required or when issuing credit notes or corrections to previous invoices.
In such cases, the invoice needs to include only the most basic information: the date of issue, the seller’s identification details, a short description of the goods or services, the total gross amount, and the applicable VAT rate. However, this does not remove the seller’s obligation to maintain proper accounting records that allow the transaction to be clearly identified.
Simplified invoices cannot be issued for intra-Community transactions — whether for dispatches (WDT) or acquisitions (WNT) — for exports outside the EU, for B2B transactions exceeding €100, or in cases involving the reverse charge mechanism. In practice, this means that sellers operating under the Amazon FBA VAT Netherlands model seldom make use of simplified invoicing. Their transactions are typically cross-border, involve higher values, and therefore fall outside the scope of these exemptions.
The Most Common Amazon Seller Mistakes – and How to Avoid Them
The most frequent invoicing errors made by Amazon sellers may appear trivial at first glance, yet they carry serious implications in the eyes of Belastingdienst, the Dutch Tax and Customs Administration. One of the most common issues involves using the wrong VAT number. Sellers operating under the Pan-European FBA programme often overlook the fact that invoices issued to Dutch customers must include a Dutch VAT number if the goods were stored in the Netherlands. Using a VAT number from another country, such as Germany, can lead the tax authorities to deem the invoices invalid and to disallow any related VAT deductions.
Another recurring mistake concerns the use of incorrect VAT rates. This problem frequently arises in product categories with ambiguous tax treatment, such as e-books or processed food. Since 2020, e-books in the Netherlands have been subject to the reduced 9 percent VAT rate, but many sellers continue to apply the standard 21 percent, as Amazon’s default settings often assign that higher rate automatically. Conversely, clothing sales, including children’s apparel, are always taxed at 21 percent, even though some sellers mistakenly assume a reduced rate applies, confusing Dutch law with the tax preferences of other EU countries.
An equally common issue is the lack of sufficient product detail on invoices. Every invoice must allow the goods to be clearly identified, which means generic descriptions are not acceptable. Belastingdienst has repeatedly emphasised that invoices should specify what the transaction concerns, preferably using the trade name, model, or SKU. Ambiguity in product descriptions can raise questions about the authenticity of sales records and lead to rejected deductions during audits.
Invoice numbering errors are also widespread. Missing numbers or duplicates are treated as red flags suggesting possible manipulation or poor recordkeeping. A company’s accounting system should generate invoice numbers in a continuous sequence and archive all issued documents in a verifiable manner.
Language is another area where sellers frequently encounter complications. Invoices may be issued in Dutch, English, or German, but during an audit Belastingdienst may request a Dutch translation. For that reason, it is best to use clear, neutral language, avoiding abbreviations or phrasing that might create ambiguity.
Problems also arise from inconsistencies between invoice data and information contained in Amazon’s sales reports, such as the VAT Transaction Reports. Discrepancies in invoice dates, VAT numbers, or tax rates can cause a mismatch between declared and reported figures, leading to automatic rejection of VAT returns or requests for clarification from the authorities.
To prevent these issues, sellers should establish a consistent internal process for reviewing invoices and reconciling them with sales data. All relevant records must be retained for a minimum of seven years, and for transactions related to real estate, the retention period extends to ten years. Invoices may be stored electronically, provided they remain easily accessible and reproducible during a tax audit.
Correct invoicing in the Netherlands is not merely a legal obligation; it is also a reflection of a company’s professionalism and reliability in the marketplace. A compliant invoice must be complete, legible, and consistent with the requirements of the Wet op de Omzetbelasting 1968, and an Amazon FBA seller remains fully responsible for its content, even when using Amazon’s automated systems.
Simplified invoices are permitted only in very limited circumstances, and the vast majority of e-commerce transactions require a full-format invoice. Seemingly minor errors — such as missing invoice numbers, incorrect VAT rates, or vague product descriptions — may appear harmless but are treated by Belastingdienst as warning signs of possible irregularities.
For businesses selling on Amazon.nl, accurate invoicing is one of the most critical aspects of sound financial and operational management. In the fast-moving world of e-commerce, it is often this attention to detail that distinguishes stable, well-run enterprises from those caught in a cycle of mistakes, corrections, and administrative setbacks.
Practical Advice for Amazon FBA Sellers
Selling on Amazon.nl offers a powerful opportunity to reach one of Europe’s fastest-growing e-commerce markets. Yet with that opportunity comes a set of tax obligations that should never be underestimated. In the context of Amazon FBA VAT Netherlands, the key to safe and efficient operations lies in understanding the rules that determine when, how, and where VAT must be accounted for. Success in this environment requires more than just reacting to problems as they arise. It calls for proactive management — planning for growth, monitoring sales thresholds, and adopting solutions that save time while reducing the risk of costly mistakes.
Monitor Your Sales Threshold and Shipping Patterns
In the FBA model, the boundary between local and cross-border sales is fluid. Since 1 July 2021, a unified EU-wide distance sales threshold of €10,000 per year (net of VAT) has applied. This limit covers the total value of all B2C sales to customers in other EU countries, rather than being calculated separately for each member state.
Once your total cross-border sales exceed this threshold, you must apply the VAT rate of the country of consumption — that is, the country where your customer is located. You can do this either by registering locally in that country or by declaring your sales through the One Stop Shop (OSS) system. The latter is generally simpler, as it allows you to report all cross-border B2C sales in a single return filed in your VAT country of identification.
However, if your goods are stored in the Netherlands under the Amazon FBA programme, the mere act of warehousing inventory there automatically creates a local VAT obligation, regardless of whether the €10,000 threshold has been exceeded. This means that even if all your cross-border sales are declared through OSS, you must still hold an active Dutch VAT number (NL) and submit local Dutch VAT returns.
Use VAT Automation Tools
For sellers operating across multiple countries, manual VAT compliance quickly becomes unmanageable. VAT automation tools are therefore not just a convenience — they are an operational necessity. These tools integrate directly with Amazon Seller Central, automatically importing data on sales, returns, fees, and inventory movements. This integration allows the software to calculate VAT due in each country and generate ready-made reports for submission to local tax authorities.
However, automation does not eliminate the need for accuracy. The data pulled from Amazon systems may not always align perfectly with financial statements or refund adjustments. Before submitting your return, it is crucial to cross-check automated calculations against the official VAT Transaction Report in Seller Central. Even minor discrepancies in dates or transaction values can result in incorrect declarations and the need for subsequent corrections.
Moreover, automation does not shift legal responsibility. Regardless of which software is used, Belastingdienst holds the seller — not the tool — accountable for the accuracy of VAT filings. Automation streamlines processes, but the ultimate responsibility for correct data and compliant returns remains entirely with the business owner.
Work with a VAT Advisor Experienced in E-Commerce
The Dutch VAT system is transparent yet highly structured, and this precision leaves little room for error. Even minor oversights can lead to penalties or administrative complications. For that reason, it is strongly advisable to work with a VAT advisor who understands the specifics of Amazon e-commerce.
An experienced advisor can guide you through VAT registration and initial filings, help you implement optimisation tools such as Article 23 import VAT deferral, and ensure your processes remain compliant. For businesses based outside the European Union, such an advisor can also act as a fiscal representative — a local intermediary authorised to handle VAT affairs and communication with Belastingdienst. This role is both a legal requirement and a practical advantage, providing the assurance that your compliance obligations are managed efficiently and professionally.
Another advantage of professional guidance lies in anticipating regulatory change. For example, from mid-2025, the Netherlands will become part of the Pan-European FBA network. The initial phase will require sellers to maintain active listings on Amazon.nl, but in time, this may also involve physical warehousing in the Netherlands. A well-informed VAT advisor can help you prepare for these transitions, adjust your business structure, and ensure your compliance framework evolves smoothly with the programme.
Maintain Records for Seven Years
Belastingdienst places significant emphasis on data retention and accessibility. Every seller registered for VAT in the Netherlands must keep accounting records for at least seven years, and for transactions related to real estate, the requirement extends to ten years.
This obligation covers not only sales and purchase invoices but also all reports generated through Amazon, particularly the VAT Transaction Reports, Inventory Reports, and Pan-EU Movement Reports, which document the transfer of goods between fulfilment centres. These records must be stored in an easily accessible and readable format, such as PDF, XML, or CSV, and must be available for immediate inspection by Belastingdienst without the need for specialised software.
In practice, this means relying solely on Amazon’s internal archives is insufficient. Sellers should regularly download and securely store copies of all relevant reports, either on local drives or in trusted cloud storage. Proper recordkeeping ensures readiness for audits and provides a verifiable trail of all commercial and tax activities.
Keep Track of Pan-EU and OSS Developments
Amazon continues to expand its Pan-European FBA network, with the Netherlands positioned as a strategic growth hub for 2025. As the country becomes integrated into the system, every participating seller will need to maintain active listings on Amazon.nl. Although physical warehousing in the Netherlands will be introduced gradually, sellers should already monitor whether their products are being transferred into Dutch territory, since VAT obligations arise immediately once stock is stored locally.
At the same time, the European Commission is advancing the VAT in the Digital Age (ViDA) initiative, which aims to extend OSS to additional types of transactions and further simplify e-commerce compliance across the EU. For Amazon sellers, this means that VAT reporting will likely become more automated but also more detailed, requiring greater consistency between invoices, transaction data, and digital records.
Operating within Amazon FBA VAT Netherlands is not only a logistical challenge but also a strategic tax responsibility. Sellers must continuously monitor the €10,000 EU distance sales threshold, make effective use of automation tools, collaborate with experienced VAT advisors, and maintain accurate, well-preserved records.
With the expansion of the Pan-EU programme and the evolution of OSS and ViDA, the European VAT landscape is becoming more unified, yet increasingly data-driven. Well-prepared Amazon sellers can use these developments to their advantage — minimising compliance risk, improving financial liquidity, and building a resilient, scalable business that thrives across the European Single Market.
Conclusion
Selling under the Amazon FBA VAT Netherlands model is not just a way to reach new customers in one of Europe’s most advanced e-commerce markets — it is also an administrative challenge that demands precision, structure, and tax awareness. The Dutch VAT system is transparent and logical, yet unforgiving to sellers who rely on intuition or postpone compliance until it becomes urgent. In the world of Amazon, where sales data is analysed automatically and tax obligations can be identified algorithmically, lack of preparation can cost far more than the effort of proper registration.
If you sell on Amazon.nl, your first step should be to determine whether your goods are stored in the Netherlands. It is warehousing, not merely selling, that most often triggers the VAT registration obligation. The moment even a small portion of your inventory is transferred to a Dutch fulfilment centre within the FBA network, a local tax liability arises. Even if you have no direct control over these logistics movements, responsibility for VAT compliance remains entirely yours.
You should also keep in mind the EU-wide distance selling threshold of €10,000 net per year, which applies to the total B2C sales value across all EU member states combined. Once this threshold is exceeded, VAT must be calculated based on the rate applicable in the country of consumption — in this case, the Netherlands if your customers are located there. The most efficient way to meet this requirement is by using the One Stop Shop (OSS) system, which allows cross-border sales to be reported through a single EU member state, eliminating the need for multiple local registrations. However, OSS does not replace local VAT registration if goods are physically stored within the Netherlands.
For businesses importing goods from outside the European Union, Article 23 remains one of the most valuable financial optimisation tools. This import VAT deferral scheme allows you to postpone payment of VAT at the border and instead declare and deduct it in your regular VAT return. The result is purely accounting-based — no real cash outflow occurs, and liquidity is preserved. For high-volume sellers, this mechanism can make the difference between a stable operation and a cash flow crisis.
Regardless of your operational model, Belastingdienst requires full and transparent documentation. Every invoice, sales report, payment confirmation, and piece of correspondence with Amazon or the tax authorities must be kept for at least seven years — or ten years for property-related transactions. Electronic archiving is permitted, but files must be stored in standard, readable formats such as PDF, XML, or CSV. The Dutch authorities do not accept improvised translations or screenshots from seller accounts; each invoice must meet formal legal standards, including accurate identification data, amounts, VAT rates, and product descriptions.
It is also unwise to rely solely on automation. While software systems can efficiently process data from Amazon Seller Central, discrepancies still occur between Amazon reports and the figures actually submitted to tax authorities. Before filing your VAT return, you should verify that all amounts, dates, and rates correspond precisely with your VAT Transaction Report. The final responsibility always rests with you — not with the technology that assists you.
Looking ahead to 2025, it is important to recognise that the Netherlands has become a mandatory market within the Pan-European FBA programme. Every participating seller must maintain active listings on Amazon.nl, and warehousing in the Netherlands will be introduced in phases. Even if your inventory is not yet stored there, it is worth preparing for the possibility that Amazon may automatically relocate your products to Dutch fulfilment centres, triggering immediate VAT implications.
For this reason, it is highly advisable to work with a tax advisor experienced in e-commerce. A knowledgeable specialist will not only help you register for VAT in the Netherlands but will also handle communication with Belastingdienst, apply for Article 23 import deferral, and, where necessary, act as your fiscal representative. With the right professional support, you can avoid costly errors that often exceed the price of good accounting advice.
The Dutch market offers exceptional opportunities but also demands accountability. Amazon increasingly conducts its own automated checks to determine which sellers are required to register for VAT in each country. Before the system identifies you, it is better to verify it yourself — and ensure your business meets all the necessary obligations. Check whether you need to register for VAT in the Netherlands — before Amazon does it for you.
