Article 23 case: import VAT deferment for a German manufacturer via Rotterdam

In this Article 23 case, Oakhill acts as general fiscal representative for a German manufacturer that imports containers from China through the port of Rotterdam, so import VAT no longer has to be prefinanced at the border.

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13-14containers per year imported via Rotterdam
~€500ktypical value per container
21%import VAT no longer prefinanced at the border
1Dutch VAT return: import VAT due and deducted at once
Article 23 case: abstract blue cityscape
Goods flow through Rotterdam, VAT flows through the return
The client

A German manufacturer importing from China

A German technology manufacturer (GmbH) that buys its products in China and ships them in full containers to Europe. To streamline its supply chain, the company wanted to import through the port of Rotterdam. It has no establishment in the Netherlands.

The challenge

Import VAT tied up working capital on every container

  • Without a licence, Dutch import VAT of 21% is due at customs clearance, for every container.
  • With around €500,000 per container, that is roughly €105,000 in VAT to prefinance each time, recovered only weeks later.
  • As a non-Dutch company, it could not apply for the Article 23 licence on its own: it needed a general fiscal representative.
  • It wanted one partner for fiscal representation, VAT returns and the coordination with customs in Rotterdam.
Our approach

One fiscal representative for licence, VAT and customs

  1. General fiscal representationOakhill acts as general fiscal representative (algemeen fiscaal vertegenwoordiger). We set up the power of attorney, the KYC file and the Dutch VAT registration in the client’s name.
  2. Article 23 licence applicationWith the Dutch VAT number in place, we prepared and filed the Article 23 licence application with the Belastingdienst, including the overview of expected import flows.
  3. Security depositThe Belastingdienst can ask for security from a fiscal representative, depending on volume and risk. In this case the approval was granted on condition of a security deposit, and Oakhill guides the client through that step.
  4. VAT compliance and customs coordinationEach month the import VAT is reported as due and deducted in the same Dutch VAT return. We coordinate with the customs broker so every import declaration carries the right licence and VAT details.
Before and after

What this Article 23 case changed for the client

Before After
Import VAT paid at the border per container Import VAT shifted to the Dutch VAT return
Roughly €105,000 prefinanced per container No import VAT prefinancing at customs
No Dutch presence or VAT number Dutch VAT registration via a fiscal representative
Several parties for VAT and customs One point of contact for fiscal representation
Unclear requirements for a foreign company A clear onboarding file and application
The result

Cash stays in the business

Article 23 approval

Approval of the licence by the Belastingdienst, subject to the security deposit.

Better cash flow

Import VAT no longer leaves the company at the border.

Compliant from day one

Dutch VAT registration, returns and reporting handled by Oakhill.

Rotterdam as gateway

A structure for regular container imports through the Netherlands.

At a glance

  • Industry: Technology manufacturing
  • Flow: China to Rotterdam, then the EU
  • Services: General fiscal representation, Article 23, VAT returns
  • Volume: 13-14 containers per year
  • Scope: Article 23, Dutch VAT return, Customs declarations
Your team

Who you work with

Every engagement is led by one of Oakhill’s two managing directors. Both work in English and Dutch from our office in Amstelveen.

Daniel J. Thijs, managing director of Oakhill Financial Services

Daniel J. Thijs

Managing director. Background in private equity and fund administration.

Richard de Ruijter RC, managing director of Oakhill Financial Services

Richard de Ruijter RC

Managing director. Registered controller (RC).

FAQ

Frequently asked questions

Short answers to the questions we hear most about this type of engagement.

What is an Article 23 licence?

The Article 23 licence lets an importer shift Dutch import VAT from customs clearance to the periodic VAT return. The VAT is reported as due and deducted in the same return, so no cash leaves the company at the border.

Can a foreign company get an Article 23 licence?

Yes. A company without an establishment in the Netherlands applies through a general fiscal representative, as in this Article 23 case. The representative files the Dutch VAT returns on the company’s behalf.

Does the Belastingdienst ask for a security deposit?

It can. Depending on volume and risk, the Belastingdienst may require security from the fiscal representative before the licence is granted.

Do you also need to file an ICP return?

Only if the goods are supplied onward to VAT-registered customers in other EU countries. The Article 23 licence itself does not create an ICP obligation.

This Article 23 case is one example of how we work. Read more about general fiscal representation in the Netherlands or about the Article 23 licence.

Free assessment

Importing into the Netherlands?

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ClientThe Car Rental Co
SkillsPhotography / Media Production
WebsiteGoodlayers.com

Project Title

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