Fiscal Representation Netherlands is a key concept for non EU companies that import goods into Europe through Dutch ports or sell to EU customers from abroad. Used correctly, fiscal representation in the Netherlands can simplify VAT compliance, unlock the Article 23 VAT deferral and significantly improve your cash flow on imports.
In this guide, we explain what fiscal representation is, when you actually need it, how the Dutch Article 23 license works and how foreign businesses can structure their VAT position to avoid unnecessary prefinancing of import VAT. If you are planning to use the Netherlands as your logistics and VAT hub for the EU, this is your starting point.
What is Fiscal Representation Netherlands?
Fiscal representation Netherlands means that a Dutch based company acts as your local VAT representative towards the Dutch tax authorities. This representative handles Dutch VAT registrations, filings and in some cases customs and import related VAT for your business. It allows a non resident company to access Dutch VAT facilities without having to build a full local finance function.
In practice, a fiscal representative in the Netherlands can:
- act as the official VAT contact with the Dutch Tax Administration
- file VAT returns and related reports on your behalf
- apply for and manage an Article 23 import VAT deferment license
- handle import VAT and onward supplies inside the EU
- help monitor that your VAT flows match your logistics flows
The Dutch Tax Administration describes fiscal representation and the requirements for a tax representative on its website, including the need for the representative to be established in the Netherlands and to provide financial security for VAT obligations.
Because of the strategic position of Dutch ports and airports, Fiscal Representation Netherlands has become a popular way for non EU businesses to access the EU market without setting up a full local entity in every country.
When do you need fiscal representation in the Netherlands?
Fiscal representation Netherlands is not mandatory in every situation. It becomes relevant in specific cases, mainly for non EU businesses that:
- import goods from non EU countries into the Netherlands
- store goods in Dutch warehouses before distributing across the EU
- sell goods B2B or B2C from stock located in the Netherlands
- want to use the Dutch Article 23 license to defer import VAT
In general, EU and non EU companies can register directly for VAT in the Netherlands without a representative. However, if a foreign company wants to use the import VAT deferment system with Article 23 and does not have a Dutch establishment, a fiscal representative Netherlands is normally required to apply for and maintain that license. For some specific activities, like certain distance sales or import flows, a fiscal representative can also become mandatory under Dutch rules.
Typical situations where fiscal representation in the Netherlands is useful include:
- an American company that imports goods into Rotterdam and sells them to customers across the EU
- a UK ecommerce seller holding stock in a Dutch warehouse for EU fulfilment
- a non EU brand that uses a Dutch 3PL to distribute to EU retailers
Import VAT without fiscal representation: pay at the border
Without an Article 23 license, the basic rule is straightforward. When you import goods from outside the EU into the Netherlands, import VAT is due at the border. You pay that import VAT to Dutch Customs when the goods are released. Later, you reclaim that VAT through your Dutch VAT return, provided the goods are used for taxable business activities.
This approach has two downsides for foreign companies:
- cash flow impact because you prefinance 21 percent import VAT on every shipment
- timing delays because it can take weeks before you effectively recover that VAT via your VAT return and refund
The Dutch Tax Administration explains that import VAT is normally paid to Customs and then deducted later as input VAT, which is administratively correct but heavy on cash flow if your import volumes are significant.
Article 23 license: VAT deferral through the VAT return
To make the Netherlands more attractive as a logistics hub, Dutch law offers a facility called the Article 23 license. This license allows import VAT to be shifted from the border to the periodic VAT return. Instead of paying import VAT to Customs, you report it in your VAT return and deduct it in the same return, resulting in a net nil payment if you have full deduction rights.
In practical terms, with Article 23:
- you no longer pay import VAT at the time of import
- you report the value of imported goods and related VAT in box 4 of your VAT return
- you deduct the same VAT as input VAT in the same return
- import VAT becomes a paper entry instead of a real cash outflow
The Dutch Tax Administration describes this system in its guidance on the Article 23 permit and confirms that it shifts payment of import VAT from Customs to the VAT return, as long as conditions are met.
Why fiscal representation Netherlands is the entry ticket
For Dutch established companies, applying for an Article 23 license is done directly with the tax authorities. Non resident companies, however, usually cannot apply themselves. They need a fiscal representative Netherlands who holds the license or applies for it on their behalf. That representative then reports imports and output supplies correctly in Dutch VAT returns.
So for many non EU importers, appointing a fiscal representative is not just a compliance choice. It is the entry ticket to using the Dutch Article 23 VAT deferral and avoiding structural prefinancing of import VAT.
Conditions for using Article 23 with fiscal representation
The main conditions for using Article 23 through Fiscal Representation Netherlands are typically:
- the company imports goods regularly into the Netherlands
- a proper administration is kept that shows total imports and related VAT
- the fiscal representative is established in the Netherlands and accepted by the tax authorities
- in many cases, a bank guarantee or security is provided for potential VAT liabilities
Applications for an Article 23 license must include practical details like the nature of the goods, the value of imports, the frequency of shipments and information about the fiscal representative. Professional tax and customs advisors often assist with this process and with setting up the right VAT and customs flows.
Types of fiscal representation in the Netherlands
There are two main forms of Fiscal Representation Netherlands in practice.
Limited fiscal representation
Limited fiscal representation covers a specific and limited set of transactions, usually import and immediate onward supply of goods. Key characteristics include:
- focus on import flows and direct onward sales or intra EU supplies
- the foreign company often does not have its own Dutch VAT number for those flows
- transactions are reported in the VAT return of the fiscal representative
- the representative is fully liable for VAT linked to those activities
This form of fiscal representation is often used by logistics providers and freight forwarders that combine customs handling, warehousing and VAT representation for their clients.
General fiscal representation
General fiscal representation covers a broader scope of activities. In that case:
- the foreign company will be registered for Dutch VAT in its own name
- the fiscal representative files the Dutch VAT return on behalf of that company
- all relevant transactions are included, such as imports, local supplies and intra EU acquisitions
- the liability of the representative is usually limited to certain VAT elements, depending on the arrangement
This model is often used when a non EU business has ongoing trade in the Netherlands or the wider EU and wants a more permanent VAT setup, including Article 23 and possibly local warehousing.
Benefits of Fiscal Representation Netherlands for your business
Using fiscal representation in the Netherlands can create several strategic advantages for non EU businesses, especially when combined with Article 23.
- Cash flow optimisation: import VAT is no longer prefinanced at the border, which frees up working capital.
- Access to the EU market via one hub: you can import in the Netherlands and then supply customers across the EU.
- Centralised VAT compliance: your fiscal representative handles VAT registrations, returns and correspondence.
- Better alignment between logistics and VAT: customs, warehousing and VAT reporting are integrated.
- Lower administrative burden: you avoid building a full internal VAT team for your Dutch activities.
International trade agencies and logistics councils regularly highlight the combination of Dutch ports, customs facilities and VAT deferral as a reason why many foreign companies use the Netherlands as their primary EU gateway.
Risks and responsibilities to consider
Fiscal Representation Netherlands also comes with responsibilities for both the foreign company and the representative.
- the fiscal representative must provide security and can be held liable for unpaid VAT
- the foreign business must maintain accurate records and share complete shipment data
- misaligned flows between customs declarations and VAT returns can trigger audits
- incorrect use of Article 23 can lead to assessments, interest and penalties
For that reason, it is important to work with a representative that combines VAT knowledge with operational understanding of your supply chain. Many issues arise not from the law itself, but from mismatches between logistics processes, invoices and VAT reporting.
How Fiscal Representation Netherlands fits into your wider finance setup
For growing international businesses, fiscal representation is only one part of the financial picture. You still need reliable reporting, cash flow planning and management steering information on top of your VAT structure.
If you want senior financial guidance without hiring a full time CFO, you can combine Fiscal Representation Netherlands with:
- CFO as a Service for strategic financial leadership and scenario planning
- Controlling as a Service for monthly reporting, reconciliations and KPI dashboards
This combination ensures that VAT, customs and financial control are aligned. It also reduces the risk that VAT structures are set up once and then forgotten in day to day operations.
FAQ about Fiscal Representation Netherlands
Is fiscal representation mandatory in the Netherlands?
Fiscal representation Netherlands is only mandatory in specific situations. For many businesses, especially those with a Dutch establishment, direct VAT registration is possible without a representative. For non EU companies that want to use the Article 23 import VAT deferral without a Dutch establishment, a fiscal representative is typically required.
Who can act as a fiscal representative in the Netherlands?
A fiscal representative Netherlands must be established in the Netherlands and must meet conditions set by the Dutch Tax Administration, such as providing financial security for VAT. Often this role is taken by specialized VAT service providers, customs agents or logistics companies with the right license and guarantees in place.
What are the main benefits of Fiscal Representation Netherlands?
The main benefits are access to the Article 23 VAT deferral, better cash flow because you do not prefinance import VAT, and centralised VAT compliance through a single Dutch contact point. For non EU companies using Dutch ports and distribution hubs, this often makes the difference between a heavy cash burden and a neutral, paper based VAT position.
What is the difference between limited and general fiscal representation?
Limited fiscal representation in the Netherlands applies to a specific scope of transactions, usually import and onward supply through the representative. General fiscal representation covers all Dutch VAT activities for a foreign company, with the foreign company having its own Dutch VAT number and the representative filing returns on its behalf.
How do I know if Fiscal Representation Netherlands is right for my business?
You should consider fiscal representation if you regularly import goods into the EU via the Netherlands, hold stock in Dutch warehouses or want to use Dutch VAT deferral facilities. A high level review of your supply chain, customer locations and VAT footprint will usually show whether a Dutch hub with fiscal representation is efficient for you.
Next step: structure your VAT and imports through the Netherlands
If you are a non EU company planning to use the Netherlands as your entry point into the EU, it pays to think about your VAT and fiscal representation setup early. The right structure can remove cash flow friction, reduce administrative effort and make your EU growth plans much smoother.
Looking for support beyond VAT and customs, such as recurring management reporting or a part time CFO to oversee the whole financial picture? Explore how CFO as a Service and Controlling as a Service can complement your Fiscal Representation Netherlands and give you a complete financial control framework.
You can reach us via the contact page to schedule an introductory call.