VAT Tax Representative

VAT One Stop Shop (OSS/IOSS): when is a tax representative still required?

OSS and IOSS simplify e-commerce VAT in Europe, but they do not replace the tax representative in all cases. Here is how to distinguish what each scheme covers.

What is the VAT One Stop Shop (OSS) in France?

The VAT One Stop Shop, or OSS, is a European scheme that came into force on 1 July 2021. It allows businesses selling goods or services to private individuals in different EU countries to declare and pay the VAT for all their countries of consumption through a single portal in their country of establishment.

In practice, a French company selling online to private individuals in Germany, Spain and Italy can declare all that foreign VAT on the French OSS portal, without having to register in each of those countries. The aim is to drastically simplify VAT management in cross-border B2C commerce within the EU.

Three OSS schemes The One Stop Shop comprises three schemes: the Union Scheme (EU companies), the Non-Union Scheme (non-EU companies for B2C services), and the IOSS (imports under €150). Each scheme has its own eligibility rules.

Limitations of the OSS for non-EU companies

The OSS is often presented as a universal solution, but its limitations are real, particularly for companies established outside the EU:

  • No access to the Union Scheme: non-EU companies cannot use the OSS Union Scheme, which is reserved for companies established in an EU member state.
  • Scope limited to B2C sales: the OSS (Non-Union Scheme) only covers services supplied to private individuals. Sales of goods are not included under this scheme.
  • Stock in France not covered: if a non-EU company stores goods in France (warehouse, Amazon FBA, etc.), this generates local taxable transactions that the OSS does not cover. French VAT registration with a tax representative is mandatory.
  • B2B sales excluded: sales to VAT-registered businesses in France do not fall under the OSS. They may be subject to reverse charge, but each situation must be analysed on a case-by-case basis.

The IOSS: a dedicated scheme for low-value e-commerce imports

The IOSS (Import One Stop Shop) is the counterpart of the OSS for imports. It applies to sales to private individuals in the EU of goods imported from third countries with a value of less than €150. It allows the seller to collect VAT at the point of sale (at the buyer's country rate) and remit it in a single monthly return.

For non-EU companies using the IOSS, registration must be done through a licensed intermediary established in the EU. This IOSS intermediary role is distinct from a standard VAT tax representative, but is often carried out by the same professionals.

SchemeFor whom?Which transactions?Intermediary required (non-EU)?
OSS UnionEU companiesIntra-EU B2C distance salesNot applicable
OSS Non-UnionNon-EU companiesB2C services in the EUNo (direct registration)
IOSSAll sellersImport of goods < €150 B2CYes (mandatory for non-EU)
VAT Tax RepresentativeNon-EU companiesAll French VAT transactionsYes (the representative themselves)

When does a tax representative remain mandatory despite the OSS?

Despite the simplification brought by the OSS, a VAT tax representative in France remains mandatory for non-EU companies in the following situations:

  • Storage of goods on French territory (own warehouse, 3PL, Amazon FBA).
  • Importation of goods into France followed by local resale (transactions "shipped from France").
  • Intra-EU acquisitions in France (purchases from EU suppliers with delivery in France).
  • Construction works or real estate-related services in France.
  • Transactions subject to French VAT for which reverse charge by the customer is not applicable.
Common mistake Believing that registering for the OSS exempts you from all local VAT obligations in France. This is a costly misconception: if you store or import goods in France, the OSS does not cover you and the absence of a tax representative exposes you to penalties.

Given the complexity of VAT rules in France, it is strongly recommended to consult an accredited DGFiP tax representative to determine the most appropriate arrangement for your situation.

Frequently asked questions

No. The OSS only covers B2C distance sales (to private individuals) within the EU. It does not cover stock held in France, B2B sales, imports above the low-value threshold, or transactions other than distance sales. In these cases, a tax representative remains mandatory for non-EU companies.
No. Non-EU companies cannot register under the OSS Union Scheme, which is reserved for companies established in an EU member state. They must use the Non-Union Scheme, which allows registration in any member state. For IOSS (imports), they must appoint a licensed intermediary established in the EU.
The IOSS (Import One Stop Shop) is a one-stop shop for VAT on low-value imports (under €150) sold to private individuals in the EU. It simplifies VAT collection at the point of import. Unlike the OSS, non-EU companies using the IOSS must appoint a licensed intermediary — a role that is similar to but distinct from a standard VAT tax representative.
No. The €10,000 threshold (below which intra-EU distance sales may be taxed in the country of origin) only applies to companies established in the EU. Non-EU companies are liable for French VAT from the very first euro of sales in France.
Yes, and this is often necessary. A company can use the OSS for its B2C distance sales while simultaneously having a tax representative for its stock in France or its B2B sales. The two arrangements are complementary, not mutually exclusive.

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