VAT Registration Basics for US Amazon Sellers Expanding to Europe: A Guide to the Six Key Countries
A US LLC or corporation can sell in Europe without a local company, but it needs a VAT number — listed in VIES — in every country where Amazon stores its inventory. For US businesses a fiscal representative is mandatory in Italy, France and Spain, and Italy also requires a €50,000 VIES guarantee.
When a US Amazon seller expands into Europe, the first thing to understand is that VAT works very differently from US sales tax — and that the registrations it requires are country by country, not EU-wide.
In this guide we compare the two systems, explain why a VIES-listed VAT number is essential on Amazon, and walk through registration in the six countries US sellers most often start with: Italy, France, Germany, Spain, the Netherlands and the United Kingdom.
How US Sales Tax Differs from European VAT
US sales tax is a state-level tax charged once, at the retail sale to the final consumer. In most states, marketplace facilitator laws require Amazon to collect and remit it on the seller’s behalf.
European value added tax (VAT) is set country by country and charged at every stage of the chain, from import through wholesale to retail. Businesses pay VAT on their sales and deduct the VAT they paid on purchases and imports. Standard rates are also much higher than US sales tax, generally 19–22%.
| US sales tax | European VAT | |
|---|---|---|
| Taxing jurisdiction | State (and county/city) | Country |
| Stage taxed | Retail sale only | Every stage, from import through distribution |
| Input tax deduction | No | Yes (including import VAT) |
| Typical standard rate | About 0–10% | 19–22% (six countries) |
| Seller obligations | Register once state nexus thresholds are exceeded | Register and file periodic returns, e.g. where inventory is stored |
In March 2025, the EU adopted ViDA (VAT in the Digital Age). From July 2028, businesses will be able to report cross-border movements of their own inventory within the EU through a single OSS return, which is expected to reduce the number of country-by-country VAT registrations. Until then, however, the current rules still apply, and building a solid understanding of the European market early on will put you in a better position to handle the major changes coming in 2028.
No Local Company Needed — Just a VAT Number in Each Country
You do not need to set up a subsidiary to start selling in Europe. Your US LLC or corporation can start doing business as it is, once it obtains a VAT number in the countries where it sells.
However, VAT numbers are not EU-wide; each country issues its own. As a rule, you must register in every country where FBA or Pan-European FBA stores your inventory. The registration office, required documents and whether you need a fiscal representative vary widely from country to country.
For B2C sales within the EU, a “deemed supplier” rule makes Amazon collect VAT on behalf of non-EU sellers. Even so, you still need a VAT registration in each country where inventory is stored, to handle imports, cross-border stock transfers and import VAT recovery.
What is VIES?
VIES (VAT Information Exchange System) is the European Commission’s system for checking the VAT numbers of businesses in the EU. To treat cross-border B2B sales and stock transfers as VAT-exempt, your VAT number must be registered in VIES.
In practice, a VIES-registered VAT number is essential for selling on Amazon. Under the Pan-European FBA terms, a VAT number entered in Seller Central is not considered valid unless it is listed in VIES (Amazon Pan-European FBA Programme Policy). Amazon checks numbers against VIES and declines any number found invalid. When that happens, you also lose access to the VAT Calculation Service (VCS) and must issue VAT invoices yourself.
In some countries (France, the Netherlands), a domestic VAT number is added to VIES automatically. In others (Italy, Germany, Spain), a separate application is required. You can check a number’s VIES status on the European Commission’s VIES lookup page. We cover the topic in more depth in VIES for non-EU companies.
Six-Country Overview for US Businesses
For US businesses, a fiscal representative is mandatory in three countries: Italy, France and Spain. Germany generally does not allow one, while in the Netherlands and the UK it is generally optional.
| Country | Where to register | VIES registration | Fiscal representative | Typical timeline |
|---|---|---|---|---|
| Italy | Revenue Agency, via the fiscal representative | Separate opt-in plus €50,000 guarantee | Mandatory | 4–6 weeks |
| France | SIEE, the tax office for non-residents (online portal) | FR number issued on registration | Mandatory (US not exempt) | 1–8 weeks |
| Germany | Bonn-Innenstadt tax office | Separate application to BZSt after the tax number | Generally not allowed | 4–6 weeks |
| Spain | AEAT (Form 036) | Separate ROI application | Mandatory | Same day possible once documents are complete |
| Netherlands | Foreign business unit (Heerlen) | NL number issued on registration | Generally optional | 2–6 weeks |
| UK | HMRC online registration | Not covered (outside the EU) | Generally optional | About 30 working days |
Timelines are indicative, based on the EY Worldwide VAT Guide 2026. Actual times depend on how complete your documents are and on the tax authority’s workload.
Italy
To obtain an Italian VAT number, a US business must appoint a fiscal representative (rappresentante fiscale). In addition, since April 2025, registering in VIES for intra-EU trade requires a €50,000 guarantee.
1. Appoint a fiscal representative
Businesses based outside the EU and EEA register and file VAT returns through an Italian fiscal representative. The representative is jointly liable with the business for VAT debts and penalties.
2. Obtain the VAT number
The representative files a declaration of start of activity with the Revenue Agency (Agenzia delle Entrate), and an IT number is issued. The standard rate is 22%.
3. VIES registration and the €50,000 guarantee
In Italy, getting a VAT number does not by itself put you in VIES. You must opt in to VIES in the declaration of start of activity.
Non-EU businesses registering through a fiscal representative must provide a guarantee of at least €50,000 lasting at least 36 months, in the form of a deposit of government bonds, a bank guarantee or a surety insurance policy. The guarantee is filed with the declaration at the provincial office of the Agenzia delle Entrate covering the representative’s tax domicile. Only once it has been checked is the number added to VIES (Agenzia delle Entrate). The full procedure is set out in our guide to Italian VAT and VIES registration.
Servix International’s service
Servix International handles everything from Italian VAT registration to VIES registration. Last year, we handled Italian VAT and VIES registration for about 20,000 non-EU sellers.
- Fiscal representation: Se&Se Auditors & Chartered Accountants S.p.A. STP, a chartered accountancy and audit firm, acts as your fiscal representative, handling registration and periodic returns.
- Surety insurance: Instead of tying up €50,000 in cash, you can meet the VIES guarantee requirement with a surety insurance policy of about €3,500.
- Identity verification: We verify your identity before registration.
- Amazon integration: We are an approved member of the Amazon Solution Provider Network, so you can grant us access through Seller Central user permissions.
- Multilingual support: We work in English, Chinese, Spanish, French, Hindi and Japanese.
France
US businesses must also appoint a fiscal representative (représentant fiscal) in France. VIES registration happens automatically together with VAT registration.
1. Appoint a fiscal representative
Non-EU businesses generally need a representative. Businesses from countries that have a mutual assistance agreement with France (such as Japan, the UK and South Korea) are exempt, but the United States is not on that list. The representative applies for appointment from its own online tax account before the VAT registration is filed, and is jointly liable for the VAT debt.
2. VAT registration
Registration is handled by SIEE, the tax office for foreign businesses, and you apply online through the one-stop portal (formalites.entreprises.gouv.fr). The main supporting documents are:
- Proof of commercial registration in your home country (for a US company, e.g. a state certificate of formation)
- Tax certificate
- Articles of association (with a French translation of the main clauses)
- Power of attorney, if applicable
- Evidence of your intention to make taxable transactions in France
Registration is free and takes about 1–8 weeks.
3. VIES
An intra-EU VAT number starting with FR is issued on registration and is normally listed in VIES as is.
Points to note
The e-invoicing obligation (issuing and receiving electronic invoices) does not apply to foreign businesses without a permanent establishment in France. However, transactions on which they owe French VAT are subject to e-reporting, which means sending transaction data to the tax authority, and this is being phased in. Large and mid-sized companies have been covered since September 1, 2026, and small and medium-sized businesses will be from September 1, 2027. B2C transactions are excluded if you are registered with an EU one-stop shop such as OSS. Data must be sent through an approved platform (impots.gouv.fr). The standard rate is 20%. More on French VAT in our France country page.
Germany
US businesses fall under the Bonn-Innenstadt tax office. Germany generally does not allow non-residents to appoint a fiscal representative; in practice, a tax adviser (Steuerberater) handles the process under a power of attorney.
1. Competent tax office
The tax office responsible for a non-resident business is set by law (UStZustV) according to its country of residence. US businesses are handled by the Bonn-Innenstadt tax office (Finanzamt Bonn-Innenstadt).
2. VAT registration (obtaining a Steuernummer)
The main documents to submit are:
- The tax office’s registration questionnaire (Fragebogen zur steuerlichen Erfassung)
- A tax certificate from your home country (for a US company, e.g. an IRS certificate of residency)
- An extract from the commercial register (e.g. a state certificate of formation)
It usually takes 4–6 weeks to receive the tax number.
3. VIES (USt-IdNr)
Once you have the tax number, you apply separately to the Federal Central Tax Office (BZSt) for a USt-IdNr, the number used for intra-EU trade. This is the number registered in VIES. The business identification number (W-IdNr), issued automatically since November 2024, does not replace the USt-IdNr.
Points to note
The rule requiring all newly registered businesses to file monthly for their first two years is suspended through the 2026 tax period. In the meantime, the normal rules apply: you file monthly if your VAT for the previous year (or the expected amount, in your first year) exceeds €9,000, and quarterly otherwise (German Federal Ministry of Finance). Check the latest information for how this will apply from 2027. The standard rate is 19%. More on German VAT in our Germany country page.
Spain
US businesses must appoint a representative with a tax address in Spain. To appear in VIES, you must also apply separately for the Register of Intra-Community Operators (ROI), a mechanism similar to Italy’s VIES opt-in.
1. Appoint a fiscal representative
Businesses established outside the EU must appoint a representative with a tax domicile (domicilio fiscal) in Spain (Agencia Tributaria). The representative can be an individual or a company, and does not need to be a Spanish national.
2. Obtain a Spanish NIF for your legal representative
If the individual representing your company does not have a Spanish tax number, apply for one using Form 030. In practice, the tax authority does not accept the registration unless the legal representative has a Spanish NIF.
3. VAT registration (Form 036)
The company applies for its tax number (NIF) using Form 036. The main supporting documents are:
- An extract from the commercial register (showing the legal representative)
- A power of attorney for the fiscal representative
- A copy of the legal representative’s passport
- Information on the beneficial owners
Documents are usually submitted in person, and registration can be granted the same day once everything is in order.
4. VIES (ROI registration)
To apply, tick box 582 of Form 036 and enter the expected date of your first transaction in box 584. If the tax authority does not decide within three months, the application is deemed rejected. Your ES number appears in VIES only once you are registered in the ROI. The standard rate is 21%. More on Spanish VAT in our Spain country page.
Netherlands
In the Netherlands, a fiscal representative is generally optional, and VIES registration happens together with VAT registration. Because a representative lets you defer import VAT, the Netherlands is often chosen as an import hub.
1. VAT registration
Foreign businesses register using the “Aanmelding Onderneming buitenland” form (an English version is available). Registration is handled by the tax authority’s foreign business unit in Heerlen and takes about 2–6 weeks.
2. VIES
On registration, you receive a btw-id starting with NL (btw-identificatienummer: the Dutch VAT identification number, shown on invoices and given to business partners, and separate from the tax number used in dealings with the tax authority), which can then be checked in VIES.
3. Fiscal representative
A representative is generally optional. However, a foreign business with no establishment in the Netherlands must appoint one to use import VAT deferral (an Article 23 licence) (Belastingdienst). Note also that using IOSS requires an intermediary in the EU.
The biggest advantage of appointing a representative is import VAT deferral. If the representative applies for an Article 23 licence, you do not pay import VAT at customs and instead account for it in your VAT return. The licence is processed within 8 weeks. The standard rate is 21%.
United Kingdom
Because the UK is outside the EU, you need a UK VAT number separate from any EU VAT numbers. There is no registration threshold for non-residents. However, when you sell UK-stored inventory to consumers through an online marketplace such as Amazon, the marketplace accounts for the VAT.
- Registration: Done through HMRC’s online service; takes about 30 working days.
- Fiscal representative: Generally optional. However, HMRC can direct non-established businesses to appoint one. Businesses based in countries with certain mutual assistance arrangements with the UK cannot be directed to do so (HMRC VAT Notice 700/1). HMRC does not publish a list of these countries, so US businesses should be prepared for the possibility of being asked to appoint one.
- VIES: GB numbers are not covered by VIES. Only businesses dealing in goods in Northern Ireland use an XI number, which can be checked under the EU framework.
- Returns: Must be filed using Making Tax Digital (MTD)-compatible software.
The standard rate is 20%. If you sell only to consumers through a marketplace, you can apply for an exemption from registration. However, you must register yourself if you sell to business customers or want to recover the VAT you paid on import (GOV.UK, VAT Notice 700/1). More on UK VAT in our United Kingdom country page.
Common Practical Points and Summary
The first step in expanding to Europe is to decide where to store your inventory, then set up a VAT number and VIES registration in each of those countries. Whichever country you start with, keep these points in mind:
- OSS and IOSS: For cross-border B2C sales from inventory in the EU, combine local registration in the storage country with the Union OSS. Goods worth €150 or less shipped from outside the EU go through IOSS, and non-EU businesses need an intermediary in the EU.
- EORI number: You need an EU EORI number for customs clearance of imports.
- Check current practice: Each country’s practice changes often. Before starting any registration, check the tax authority’s current requirements.
For US businesses, Italy, France and Spain are the countries where a fiscal representative is mandatory. Italy also requires the VIES guarantee. Servix International supports you end to end in Italy, from VAT and VIES registration through arranging the surety insurance to filing periodic returns. If you are planning your Amazon expansion into Europe, we would be glad to hear from you.
Sources
- EY Worldwide VAT Guide 2026
- Official websites of the tax authorities of France, Germany, the Netherlands, Spain and the UK
- Agenzia delle Entrate: VAT registration of non-residents through a fiscal representative
- Amazon Pan-European FBA Programme Policy
- European Commission VIES lookup
Planning your entry into the Italian market?
Tell us about your business and our team will map the VAT, VIES and guarantee steps for your case — usually within one business day.