EU IOSS Signup

[Graham Wharton]

Has anyone found a way to sign up to the IOSS system in the EU without having to appoint an EU VAT intermediary. The guidance says it is not necessary to have an intermediary if there is a vat mutual assistance agreement, which the EU and UK now have.

 

[Graham Wharton]

Find attached response from Irish Revenue regarding application for IOSS without appointing an EU VAT Intermediary.

Dear Graham,

I refer to your e-mail below.

At present, we are waiting confirmation on whether or not UK traders will need to use an intermediary to register for the Import Scheme.

The advice to UK traders to hold off applying for the Import scheme (via an intermediary) until we receive confirmation on the matter.

Regards,

Office of the Revenue Commissioners, Government Buildings, Millennium Centre, Dundalk, Co. Louth, Ireland.​

 

[ADC]

Apparently Ireland are expecting a decision from the EU by 30th April. Now the EU commission has ratified the trade agreement, I would expect an answer in the next few days.

 

[ADC]

Has anyone found a way to sign up to the IOSS system in the EU without having to appoint an EU VAT intermediary. The guidance says it is not necessary to have an intermediary if there is a vat mutual assistance agreement, which the EU and UK now have.

Do you sell products that need a CE certification? Have you appointed an EU responsible person for that? Apparently you have to do it by July 21st.

 

[Graham Wharton]

My products are chemicals. All manufactured in the EU by mainstream manufacturers. I buy in bulk, split and sell back to consumers. I provide the manufacturers MSDS but no further certs. None are classified as hazardous for transport. I apply all product labelling as required by MSDS. I'm not aware I need to do any more. I only repackage, I don't alter the product.

 

[ADC]

My products are chemicals. All manufactured in the EU by mainstream manufacturers. I buy in bulk, split and sell back to consumers. I provide the manufacturers MSDS but no further certs. None are classified as hazardous for transport. I apply all product labelling as required by MSDS. I'm not aware I need to do any more. I only repackage, I don't alter the product.

You should be alright with chemicals, I think. You can always use the manufacturer for your Responsible Person anyway.

We sell electrical items manufactured in China, so a bit more hassle for us.

 

[Graham Wharton]

Thanks for the followup. It is quite often the only time you find out that you should be doing something, when chatting like this. Requirements can be hidden away, with governing bodies just assuming you know where to look with no advertising of the requirements.

 

[JPMiddleton]

Have you heard any more about this? There does appear to be a lack of awareness and understanding regarding this new system. I see Royal Mail's DDP page now mentions the IOSS system also....

https://www.royalmail.com/business/international/guide/delivered-duties-paid

The Import One Stop Shop (IOSS)
The Import One Stop Shop (IOSS) is being introduced by the EU, to enable and simplify the declaration and payment of VAT for distance sales of imported goods – with a value up to €150.

The Import One Stop Shop (IOSS) is the electronic portal, your business can use from 1 July 2021 to comply with the new VAT e-commerce obligations on distance sales of imported goods. Once registered for IOSS, VAT can be collected at the checkout and paid directly to EU customs authorities in quarterly, EU, VAT returns. No additional customs handling fees will be applied when the parcels arrive in the EU customs facility, speeding up the release into free circulation of the goods to your customer.

Royal Mail are currently working hard behind the scenes on how you send items with us under the IOSS scheme, should you register yourself, but also to assist you in registering with and operating within the IOSS framework. These solutions will allow goods to be sent to customers in the EU with VAT paid – quickly and simply. Items valued over €150 will need to be sent DDU or as postal DDP. Once these are fully tested and operational, we will provide further details here on the Royal Mail website.

The new rules will transform how you do business in the European Union. You can find more information about these changes hereOpens in a new window that the European Commission has published.

 

[Graham Wharton]

I know the new DDP (Delivered Duty Paid) option from Royal Mail will be able to be used for items above 150EUR going to europe, and the VAT and Duty can be paid in advance by yourself along with a small admin fee as part of the sending process (You pay the VAT and Duty to Royal Mail, and they pay the EU). You don't have to use this service, and if you don't the Duty and VAT will be collected at the border and billed to the receiver with an Admin fee DDU (Delivered Duty Unpaid)/DAP (Delivered at Place). These items are excluded from IOSS as they are above 150 EUR. The DDP service isn't quite live yet, DDU/DAP are just the regular post options to the EU.

This is completely separate from IOSS which can be used to pay the VAT on items below 150EUR where no duty is due. With IOSS you pay the VAT to your intermediary, or direct to the EU. No payments go to Royal Mail with IOSS.

Once you are successfully signed up to IOSS, you will be issued with an IM******** VAT number from either your VAT Intermediary, or direct from the EU member state. IM standing for Import.

You should enter your IM********** VAT number under the C&D Settings -> Trading Names -> Pre Registration Tax Schemes. The IM*********** VAT Number will appear on any CN22, CN23 paperwork generated, and will also be included in the electronic data. The Australia, New Zealand and Norway schemes can also be added in addition to the EU IOSS Scheme if you are registered in them aswell. Presumably customs in the EU will see the fact that there is an IOSS IM********* VAT number associated with the item, and if the value is below 150EUR, it will just be waived straight through as they know VAT has already been paid.

As far as being actually able to sign up to IOSS without using an intermediary, no news as yet as far as I can see. I have made contact with the Federation of Small Businesses (FSB)'s EU Expert who is making enquiries with the European Commission directly. If I get any updates, I will drop them here.

 

[JPMiddleton]

Yeah, I understand how it works (we use DDP with DHL) and how IOSS is going to work, but the link does cite IOSS as there will be a specific need for RM and for EU postal services (and couriers) to know when an item has had it's VAT paid at the time of purchase and not when it arrives, thus not needing a customs handling charge.

As far as I can see this is the issue that is most likely to cause problems.

 

[JPMiddleton]

Specifically, I am interested in if anyone knows if an intermediary is needed to register for IOSS or if we can go ahead and do it ourselves.

 

[Graham Wharton]

I believe we should be finding out soon if that is going to be possible. In the meantime, I was advised by Irish Revenue, not to spend any money appointing an intermediary at this time. We've still got just under 2 months until it goes live, so hopefully enough time to sort out the details and start accepting UK applications directly.

The only thing that is making me hesitant, is the fact that Norway has had a VAT Mutual Assistance agreement for a while now, and I don't see any options on any member state website to allow Norwegian small businesses to sign up. Perhaps they were waiting for someone larger to come along before spending the money on the web portal?

 

[JPMiddleton]

Have just spoken with our RM account manager, who was fresh off a morning conference call and brought this up.

It would appear that RM are going to facilitate applications for IOSS as a third party intermediary, and then it's a case of paying the VAT return once a quarter. She's double checking, but is pretty sure the number will be fine to use for non-RM stuff (wouldn't make sense not to).

Once the application is complete the IOSS number will be included on the parcel.

They're not sure when it's going to be ready, but it seems it's yet another rush. If this was ready on July 1st as initially intended we'd have seem much less 'friction' exporting parcels to the EU. Begs the question, did they delay to add in some extra friction intentionally between the UK and EU for a few months!

 

[Graham Wharton]

Thats interesting, but presumably only for parcels sent via RM. I would need a different solution for my other couriers.

 

[JPMiddleton]

I don't think so, RM will help you get an IOSS number and then you can use for all couriers. She is confirming and double checking this, it wouldn't make sense for the EU to ask us to reg' once on IOSS to pay VAT for RM parcels and then another registration for another courier, and so on.

 

[JPMiddleton]

Our DHL account manager also just confirmed they're ready... they have added an IOSS number field and it will be added to their labels and treated as VAT paid.

 

[Graham Wharton]

It is my understanding that if Royal Mail are acting as an intermediary, then they become legally responsible for the EU VAT collected under the scheme. Perhaps they are not full intermediaries under their proposed scheme. I guess thats what they are trying to work out.

 

[Graham Wharton]

Yeah, I saw the DHL entry on the portal this week.

I applied for the Norway VOEC scheme but was turned down as my products are dutiable in Norway. The only other two schemes I know of are NZ and AU, but I dont ship enough over there to be worthwhile.

 

[JPMiddleton]

Yeah, she just clarified that they're merely providing information as to how to do it easily and they're not acting on behalf of anyone.

 

[schmexit]

I'm also interested in this. Ireland says you must have an intermediary. However, EU's Explanatory Notes on VAT e-commerce rules say:

(can't post link but if you Google the text, it comes up)

"Member States may not oblige non-EU suppliers to appoint a tax representative to use the non-Union scheme (Article 204 of the VAT Directive)."

Shouldn't this then apply?

 

[Graham Wharton]

Response from European Commission via Federation of Small Businesses.

I’ve received the below response from the European Commission:​

The new rules on VAT ecommerce (Directive (EU) 2017/2455 as regards certain value added tax obligations for supplies of services and distance sales of goods) will come into force on 1 July 2021. To make use of the special scheme for distance sales of goods imported from third territories or third countries, traders established in third territories or third countries must appoint an intermediary established in the European Union as the person liable for payment of the VAT under the IOSS.

Indeed, pursuant to Article 369m of the VAT Directive, there is no need to appoint such an intermediary if the trader is established in a country with which the Union has concluded an agreement on mutual assistance similar in scope to Council Directive 2010/24/EU and Regulation (EU) No 904/2010.

However, for the full implementation of Article 369 m, the Commission shall establish the list of third countries with which the Union has concluded an agreement on administrative cooperation and recovery assistance, similar in scope to the legislation in place among the Member States. That is why the Commission has proposed a Council Decision with the list of such countries which is currently in the process of adoption. The adoption of the decision is foreseen by the entry into force of the new VAT rules (at the latest by the end of June).

We will be in a position to provide you with more information after the adoption procedure is finalised.​

So, essentially, we are waiting for the EU to approve that draft Council Decision referenced above before Member States will have absolute certainty that UK firms won’t require an intermediary. This might explain the response from the Irish tax office.

If that seems a slightly circuitous way round to you, then you’re not alone(!).

We’ll keep an eye on progress of the Council Decision, and I’ll be sure to let you know regarding future developments. I hope this is helpful.​

So looks like we have to hang fire for now. Once the EU have established and published the Article 369m list of 3rd countries that dont need intermediaries, then things might start to move. Depends on how quickly after that list is published, that the systems in each of the member states websites will be updated to allow us to sign up. I would hope that the Irish Revenue and Swedish Tax Office websites would be the first ones to go as I believe it is only Norway and the UK that are on this Article 369m List. I'll keep this post updated with any info I get.

 

[Graham Wharton]

"Member States may not oblige non-EU suppliers to appoint a tax representative to use the non-Union scheme (Article 204 of the VAT Directive)."

Also note that references to the Union and Non-Union Scheme don't apply to people shipping goods to the EU. People supplying goods need to sign up for the IOSS (Import One Stop Shop) Scheme. The Non-Union scheme is for UK businesses supplying digital services to the EU and is part of the existing MOSS (Mini One Stop Shop) scheme, which will be renamed to the OSS (One Stop Shop) Scheme. Urghhhh.... Too many acronyms. Your point applies to all schemes, but its important to get the the right scheme when you register.

Searching for "eu the new oss schemes taxation customs union" in google, first result gives a good summary of how the schemes overlap

 

[schmexit]

@Graham Wharton - thanks so much for that! At least that explains the conflicting information. What a mess!

Yes, please do keep us updated if you hear any news.

By the way, would Ireland be the best/easiest choice for IOSS registration?

 

[JPMiddleton]

eBay update on IOSS.. i've not read it yet but thought it may be useful.

https://www.ebay.co.uk/help/listings/default/vat-obligations-uk-eu?id=4650

 

[Ty_123]

Hi there,

I know we're all waiting for an updated list of countries which, the Union has concluded an agreement on mutual assistance similar in scope to Council Directive 2010/24/EU and Regulation (EU) No 904/2010. To see if the UK is in the new list.

But does anyone know if there is a published list already of established countries?

Thank you for your help.

 

[Ty_123]

Is it this list?

Chart of signatures and ratifications of Treaty 127

 

[Nathan89]

Has anyone signed up for IOSS yet? It's nearly July 1st, there doesn't seem to be any way to do it, I have tried the irish website like others have said when you go through it's about the vat one stop shop not the import OSS

 

[romeo b]

This is extremely frustrating and going to cause even more problems than exist already.

We're small business, not UK-vat reg'd, but being told we need to do the IOSS sign up.

The IOSS place (Ireland) told us this just now:

----
VAT registration is not a determining factor for the OSS / IOSS schemes and, unlike domestic stipulations, no thresholds apply. In that regard, all goods / services sold B2C to the EU are to be declared.

As you are shipping goods, either the Union OSS scheme and / or the Import (IOSS) scheme can be registered for.

If you are shipping goods intra-EU then you may register for theUnion VAT OSSscheme In the first instance in a Member State in which you have an establishment or, otherwise, in the Member State in which the goods are based.

If you are shipping goods from the UK or another third country to the EU you may register for theImport (IOSS)scheme. Goods must be in consignments of a value not greater than €150 and registration can be in any Member State in which the business has an establishment.

Please note, however,that if the business has no establishment in the EU, it must register indirectly viaan entity (appointed by the business) that has an establishment in the chosen Member State. For IRL, that entity must also have a Revenue-issued Tax Advisory Identifier Number (TAIN) before they apply to register as an intermediary. The intermediary will then submit the application on the business’s behalf.
----

So we need to find someone Irish-based to do it? Is this the way forward for every small business just to send £10-20 items to France, Spain and Germany? It's utterly ridiculous and just kills everything.

EDIT: What's the deal with Zero-rating stuff too? Would that stop all our customers with the VAT issue? It's super confusing for a normal person who ships small goods to understand. HMRC say things sent via post is zero rated. Man this is confusing.

 

[schmexit]

This is extremely frustrating and going to cause even more problems than exist already.

We're small business, not UK-vat reg'd, but being told we need to do the IOSS sign up.

The IOSS place (Ireland) told us this just now:

----
VAT registration is not a determining factor for the OSS / IOSS schemes and, unlike domestic stipulations, no thresholds apply. In that regard, all goods / services sold B2C to the EU are to be declared.

As you are shipping goods, either the Union OSS scheme and / or the Import (IOSS) scheme can be registered for.

If you are shipping goods intra-EU then you may register for theUnion VAT OSSscheme In the first instance in a Member State in which you have an establishment or, otherwise, in the Member State in which the goods are based.

If you are shipping goods from the UK or another third country to the EU you may register for theImport (IOSS)scheme. Goods must be in consignments of a value not greater than €150 and registration can be in any Member State in which the business has an establishment.

Please note, however,that if the business has no establishment in the EU, it must register indirectly viaan entity (appointed by the business) that has an establishment in the chosen Member State. For IRL, that entity must also have a Revenue-issued Tax Advisory Identifier Number (TAIN) before they apply to register as an intermediary. The intermediary will then submit the application on the business’s behalf.
----

So we need to find someone Irish-based to do it? Is this the way forward for every small business just to send £10-20 items to France, Spain and Germany? It's utterly ridiculous and just kills everything.

EDIT: What's the deal with Zero-rating stuff too? Would that stop all our customers with the VAT issue? It's super confusing for a normal person who ships small goods to understand. HMRC say things sent via post is zero rated. Man this is confusing.

It is 100% ridiculous. Small businesses are left in the lurch with no clear answers or guidance.

 

[Nathan89]

Agreed it is frustrating, we already have VAT numbers for 6 other countries so we may be able to signup through them, Ireland would be the best one to do it with because of the language advantage however we aren't registered for VAT there

why doesn't the EU just make a standard portal and take all the money directly instead of messing around

 

[schmexit]

The EU are not doing a great job with this, but I really blame the UK government. They should have thought about small businesses more when negotiating the deal we have, and they should be providing more guidance right now.

 

[Nathan89]

I don't think it's just small business though, i've seen a lot of big businesses no longer willing to export to the EU on their websites either the market was too small or they just didn't think it was cost effective to manage it

I think the EU are looking more at the marketplaces than sellers, probably accounts for 50% or more of the sales

 

[schmexit]

That's true. If big businesses are struggling, what are the rest of us supposed to do?

 

[romeo b]

I've asked the Irish tax office, Royal Mail, HMRC, eBay and nobody has the same answer and rarely reply properly anyway.

How are we even meant to continue trading with Europe when it's in this state of affairs?

To say I am concerned is an understatement, given 70% of our trade is sending stuff to France, Spain, Portugal, Germany etc.

As said there should really just be a central portal and anyone can go there, register, and it's handled.

I'm just waiting really but not sure what for. Totally in limbo right now.

 

[schmexit]

I've asked the Irish tax office, Royal Mail, HMRC, eBay and nobody has the same answer and rarely reply properly anyway.

How are we even meant to continue trading with Europe when it's in this state of affairs?

To say I am concerned is an understatement, given 70% of our trade is sending stuff to France, Spain, Portugal, Germany etc.

As said there should really just be a central portal and anyone can go there, register, and it's handled.

I'm just waiting really but not sure what for. Totally in limbo right now.

Same situation here. Hoping that Ireland will recognise that there's no need for a fiscal rep and we can register there. Also hoping that Royal Mail will be ready for IOSS by July. Not sure what else I can do in the meantime.

 

[akford91]

This is extremely frustrating and going to cause even more problems than exist already.

We're small business, not UK-vat reg'd, but being told we need to do the IOSS sign up.

The IOSS place (Ireland) told us this just now:

----
VAT registration is not a determining factor for the OSS / IOSS schemes and, unlike domestic stipulations, no thresholds apply. In that regard, all goods / services sold B2C to the EU are to be declared.

As you are shipping goods, either the Union OSS scheme and / or the Import (IOSS) scheme can be registered for.

If you are shipping goods intra-EU then you may register for theUnion VAT OSSscheme In the first instance in a Member State in which you have an establishment or, otherwise, in the Member State in which the goods are based.

If you are shipping goods from the UK or another third country to the EU you may register for theImport (IOSS)scheme. Goods must be in consignments of a value not greater than €150 and registration can be in any Member State in which the business has an establishment.

Please note, however,that if the business has no establishment in the EU, it must register indirectly viaan entity (appointed by the business) that has an establishment in the chosen Member State. For IRL, that entity must also have a Revenue-issued Tax Advisory Identifier Number (TAIN) before they apply to register as an intermediary. The intermediary will then submit the application on the business’s behalf.
----

So we need to find someone Irish-based to do it? Is this the way forward for every small business just to send £10-20 items to France, Spain and Germany? It's utterly ridiculous and just kills everything.

EDIT: What's the deal with Zero-rating stuff too? Would that stop all our customers with the VAT issue? It's super confusing for a normal person who ships small goods to understand. HMRC say things sent via post is zero rated. Man this is confusing.

I'm not entirely sure why the Irish Revenue Commissions are advising you must apply for OSS or IOSS if you are sending goods B2C as the EU's guidance titled "Importation and Exportation of Low Value Consignments – VAT E-Commerce Package "Guidance For Mss and Trade"" clearly states on page eight:

The use of the IOSS is not mandatory but there are fiscal and customs incentives that should encourage businesses to use it.

Unfortunately, as a new user I'm unable to post a link to this document. However, if you type "iOSS mandatory" into Google, it's the first link which is shown with the above quote.

 

[romeo b]

I'm not entirely sure why the Irish Revenue Commissions are advising you must apply for OSS or IOSS if you are sending goods B2C as the EU's guidance titled "Importation and Exportation of Low Value Consignments – VAT E-Commerce Package "Guidance For Mss and Trade"" clearly states on page eight:



Unfortunately, as a new user I'm unable to post a link to this document. However, if you type "iOSS mandatory" into Google, it's the first link which is shown with the above quote.

They said in a second email to me, when I mentioned about conflicting information regarding holding off registering and what's been mentioned on here about it not being required if we (UK) end up on this previously mentioned magic list of countries:

---
It’s a matter for businesses themselves as to when they register for the scheme and IRL, like other interested parties, awaits the outcome of the process highlighted below.

In the absence of same, the current requirement is that, Norway being an exception, a non-EU business that does not have an establishment in the EU must engage an intermediary for IOSS purposes.
----

So, it sounds like they're just saying it's going to be required as nothing exists *yet*, but if it's decided we don't need to appoint people, we can just apply as normal on our own behalf.

It doesn't actually solve the problem though.

I'm also trying to get to grips with the "zero rated" VAT side of things; HMRC says:

HMRC says: VAT is a tax levied on goods and services consumed in the UK. When goods are exported they are ‘consumed’ outside the UK and to impose VAT on such goods would be contrary to the purpose of the tax. Therefore, the supply of exported goods is zero-rated provided the conditions in this notice are met.

A zero-rated VAT supply is one which is subject to VAT but where the VAT is at 0%.

It's extremely confusing and we're pretty much just relying on people talking in common sense rather than riddles at the moment, mainly on here from what we're taking advice from.

If anyone can get to grips with the Zero rating and explain it like I'm 5 that would be appreciated!

 

[schmexit]

I'm not entirely sure why the Irish Revenue Commissions are advising you must apply for OSS or IOSS if you are sending goods B2C as the EU's guidance titled "Importation and Exportation of Low Value Consignments – VAT E-Commerce Package "Guidance For Mss and Trade"" clearly states on page eight:



Unfortunately, as a new user I'm unable to post a link to this document. However, if you type "iOSS mandatory" into Google, it's the first link which is shown with the above quote.

Of course, IOSS is not mandatory, but it allows for a much smoother experience for EU customers. So most businesses sending to the EU will want to register - but not if a fiscal rep is required, which is the main issue here.

 

[akford91]

Of course, IOSS is not mandatory, but it allows for a much smoother experience for EU customers. So most businesses sending to the EU will want to register - but not if a fiscal rep is required, which is the main issue here.

I wasn't questioning that most businesses would like to register for IOSS. However, I was only pointing out that if the Irish Revenue Commissioners are misadvising people about the rules of applying for OSS and IOSS (in this case, stating it's mandatory when it's not) then it highlights what a mess the OSS and IOSS system is and how the Irish Revenue Commissioners don't seem to have the correct information either.

 

[schmexit]

I wasn't questioning that most businesses would like to register for IOSS. However, I was only pointing out that if the Irish Revenue Commissioners are misadvising people about the rules of applying for OSS and IOSS (in this case, stating it's mandatory when it's not) then it highlights what a mess the OSS and IOSS system is and how the Irish Revenue Commissioners don't seem to have the correct information either.

I think we can all agree on one thing: It's a complete mess!