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EU VAT, OSS and IOSS for marketplace sellers in 2026: what marketplaces collect and what you still owe

A practical 2026 guide to the EU VAT package for marketplace sellers: how OSS replaces 26 distance-selling registrations, where IOSS fits for sub-EUR 150 imports, and where deemed-supplier rules leave the seller still on the hook. Covers local-storage triggers, B2B carve-outs, the quarterly return reality, and the documentation marketplaces and tax authorities now expect. Written for brands selling across Amazon, bol, Kaufland, Zalando and the rest of the EU marketplace stack.

By Operator One Editorial — 2026-06-14

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Five years into the EU's e-commerce VAT package, most marketplace sellers can describe what OSS stands for, but very few can confidently say what it does not cover. That gap is where the real exposure sits — in stranded local registrations, mis-routed B2B invoices, IOSS numbers used on parcels they were never meant to clear, and deemed-supplier assumptions that leave the seller carrying the VAT the marketplace already collected.

This piece walks through the regime as it actually operates in 2026: the legal foundation, the thresholds that matter, when OSS is the right answer, when it is the wrong one, and what marketplaces collect on your behalf versus what stays your obligation.

The 2021 package, five years in

The current architecture comes from Council Directive (EU) 2017/2455 and its companion 2019/1995, applied from 1 July 2021. It did four things that still shape every cross-border filing decision today:

  • Abolished the patchwork of national distance-selling thresholds (the old EUR 35,000 / EUR 100,000 country grids) and replaced them with a single EU-wide threshold of EUR 10,000 per calendar year for intra-EU B2C distance sales of goods plus telecom/broadcasting/electronic services.
  • Extended the Mini One-Stop-Shop (MOSS) into a full One-Stop-Shop, the Union OSS, covering goods and most B2C services.
  • Created the Non-Union OSS for B2C service providers established outside the EU.
  • Introduced the Import One-Stop-Shop (IOSS) for distance sales of imported goods in consignments of intrinsic value up to EUR 150, and removed the old EUR 22 low-value-consignment relief.

The package also embedded the deemed supplier rule into Article 14a of the VAT Directive. Where a marketplace "facilitates" certain B2C supplies, the marketplace is treated for VAT purposes as if it bought the goods from the underlying seller and resold them to the consumer. That shift in legal supply is the single most misunderstood mechanic in EU e-commerce VAT today, and we come back to it below.

When OSS is the right answer

Union OSS is designed for one specific situation: you are shipping goods from one EU country to a consumer in another EU country, and you want to report the destination-country VAT through a single quarterly return in your country of identification rather than registering locally everywhere you ship.

OSS works cleanly when:

  • You hold stock in one EU country only — typically your home market, or a single 3PL hub.
  • Your annual cross-border B2C turnover into other EU member states exceeds EUR 10,000, so destination-country VAT is mandatory rather than optional.
  • You sell only to consumers, or your B2B share is small and properly invoiced under standard cross-border rules outside OSS.
  • You ship from inside the EU only — OSS does not cover goods physically dispatched from the UK, Switzerland, the US, or any other third country.

Below the EUR 10,000 micro-business threshold, you are allowed to keep charging your home VAT rate on cross-border B2C sales. Most marketplace sellers cross that line in the first quarter of trading, so the threshold is mostly a transitional comfort rather than a strategy.

When OSS is the wrong answer

OSS is a reporting wrapper, not a substitute for being VAT-registered where the law says you must be. The most common situations where a seller still needs a local VAT number — and where assuming OSS covers it creates real liability — are:

  • You hold stock in that country. Amazon FBA, Pan-EU, Central European Programme, bol LVB, and any local 3PL trigger a local VAT registration the moment inventory lands. OSS does not cover domestic supplies (goods that start and end in the same country) and it does not cover intra-community movements of your own stock between fulfilment centres.
  • You sell B2B. Cross-border B2B supplies of goods are reverse-charge transactions reported through your local VAT return and EC Sales List, not through OSS.
  • You ship from outside the EU and the consignment is over EUR 150. These clear under standard import VAT rules with the importer of record paying VAT and duty at the border. IOSS does not apply, and OSS does not apply either.
  • You operate a marketplace yourself, or sell through one where the deemed-supplier rule does not apply (for example, intra-EU B2C sales by an EU-established seller through a marketplace — the seller, not the marketplace, remains liable).

This is also where the local-storage and OSS regimes most often collide in practice: a brand registers for OSS, ships into Amazon's Central European Programme, and then discovers six months later that Polish and Czech VAT numbers were required from day one of stock arriving in those warehouses.

IOSS: the EUR 150 import lane

IOSS is the import-side counterpart to OSS, and it has a much narrower scope than most non-EU sellers assume. It covers distance sales of goods imported from a third territory or third country, in consignments of an intrinsic value not exceeding EUR 150, excluding excise goods.

Used correctly, IOSS lets the seller (or the marketplace acting as deemed supplier) charge destination-country VAT at checkout, transmit the IOSS number to the customs declarant, and have the parcel clear without VAT being collected again at the border. The customer sees a single VAT-inclusive price and no surprise handling fees.

Three failure modes are common in 2026:

  • IOSS number misuse. A marketplace's IOSS number can only be used for parcels that arise from sales the marketplace facilitated. Using it on direct-to-consumer parcels from your own webshop is a misuse that the customs authorities increasingly catch through e-commerce data sharing.
  • Splitting consignments above EUR 150. The threshold is per consignment, not per item. Breaking an EUR 220 order into two parcels to slip under EUR 150 each is treated as abuse.
  • Excise and restricted goods. Alcohol, tobacco, perfume and certain other categories are excluded from IOSS regardless of value.

What the marketplace collects, what you still owe

Under Article 14a, the marketplace becomes the deemed supplier — and therefore liable for output VAT to the consumer — in two scenarios:

  • Distance sales of imported goods in consignments up to EUR 150, where the marketplace facilitates the sale.
  • Any B2C supply within the EU (domestic or intra-EU) where the underlying seller is established outside the EU.

Outside those two cases — most importantly, intra-EU B2C sales by EU-established sellers — the seller remains the VAT-liable party. The marketplace will still issue invoices and collect funds, but legally the supply is yours and the VAT is yours.

Even where the marketplace is deemed supplier, the underlying seller is treated as making a zero-rated B2B supply to the marketplace. That supply must be reported, evidenced, and reconciled — it does not disappear from your books just because the consumer-facing VAT is the marketplace's problem. For EU-established sellers, this reporting flows through standard domestic returns. For non-EU sellers, it usually still requires an EU VAT number to evidence the upstream zero-rated supply.

The quarterly OSS return in practice

The OSS return looks deceptively simple — one filing per quarter, due by the end of the month following the quarter end, payment in a single currency to your country of identification, which then redistributes to the destination tax authorities. The friction sits in three less-visible places:

  • Data reconciliation. The return is destination-country and rate-bracket specific. Amazon, bol, Kaufland, Zalando, Allegro and the rest each report taxable bases on slightly different timing and refund logic. Without a single ledger that consolidates them, the OSS return is reconstructed from spreadsheets every quarter.
  • Returns and refunds. Corrections to prior-period sales are made through subsequent returns, not by amending the original. The audit trail back to the original transaction needs to survive three years minimum.
  • FX. All amounts in the return are expressed in the currency of the country of identification, using the ECB rate of the last day of the reporting period — not the rate at the date of the sale.

For a brand selling across ten EU marketplaces, the quarterly OSS return is rarely the bottleneck. The bottleneck is the data pipeline feeding it.

Where Operator One fits

Operator One has acted as merchant of record for brands on European marketplaces since 2021, with the legal entity and VAT footprint to absorb OSS, IOSS, local registrations and the deemed-supplier reconciliation in one place. For brands already trading across the 100+ marketplaces we cover in the 27 EU member states and the UK, the VAT mechanics described above sit inside our merchant-of-record service rather than landing on the brand's own finance team — see the compliance glossary for the underlying definitions.

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