EU clarifies Jan 2027 ViDA Single VAT Registration changes

Whilst the Notes are not legally binding, they provide the clearest indication yet of how businesses should apply this first reform which is part of the EU VAT in the Digital Age ViDA reforms.

The paper explains how the existing One Stop Shop (OSS), Import One Stop Shop (IOSS) and deemed supplier rules evolve under ViDA’s first implementation phase. It also confirms that further guidance will be needed ahead of the much broader SVR reforms due from 1 July 2028.

Eight key changes from January 2027

1. The €10,000 threshold becomes much narrower

One of the biggest practical changes concerns the OSS threshold.

Only intra-EU distance sales dispatched from the Member State where the supplier is established count towards the €10,000 threshold. Goods supplied from stock held in another Member State are excluded from the calculation and instead follow the normal destination VAT rules. The Commission also confirms that businesses registering for the Union OSS automatically waive use of the threshold.

2. Union OSS becomes the default reporting mechanism – TOOG

The revised guidance reinforces the Commission’s objective of making Union OSS the primary reporting system for cross-border B2C transactions, reducing the need for multiple VAT registrations. Businesses using warehouses across the EU should reassess whether expanded OSS can replace existing local registrations. This reform covers OSS for reporting Transfer of own Goods.

3. Temporary OSS relief for energy suppliers

Until 30 June 2028, cross-border supplies of gas, electricity, heat and cooling energy to consumers and certain exempt organisations will be treated as distance sales. This enables suppliers, including operators of electric vehicle charging networks, to report VAT through Union OSS rather than registering in every Member State where charging takes place.

4. Marketplaces face greater clarification on deemed supplier rules

The Commission provides extensive guidance on determining which marketplace becomes the deemed supplier where multiple electronic interfaces are involved, alongside clearer rules on liability, invoicing and record keeping. It also confirms that ViDA extends deemed supplier treatment to supplies made to the so-called “Group of Four”, including certain exempt organisations and SMEs.

5. IOSS administration becomes tighter

The guidance clarifies several practical issues surrounding IOSS, including intrinsic value calculations, discounts, exchange rate fluctuations, split consignments and multiple orders. It also confirms that businesses using the EU SME exemption cannot simultaneously use IOSS and introduces measures to combat abuse of IOSS VAT identification numbers.

6. Chargeable event harmonisation for Union and non-Union OSS supplies, removing Member States’ ability to apply alternative Article 66 timing rules;

7. Non-Union OSS covers B2C services supplied in the EU regardless of where the customer is established or resident. The Commission gives the example of an American business supplying electronic services to American tourists while they are in the EU;

8. VAT refund routs clarification routes for businesses using Union OSS, non-Union OSS and IOSS.

Preparing for the July 2028 phase

Perhaps the most significant statement appears at the beginning of the document. The Commission explicitly acknowledges that these Notes only address the SVR changes applicable from 2027 and that a further comprehensive revision will be required for the wider Single VAT Registration reforms entering into force from 1 July 2028.

For businesses trading across multiple EU Member States, the revised guidance provides welcome certainty ahead of January’s reforms. However, it also signals that the current changes are only the first stage of a much larger transformation of the EU VAT registration landscape.