International Tax Services: Fiscal Representation and Article 23

Oakhill handles Article 23, fiscal representation, Dutch VAT, corporate income tax and Pillar Two for foreign companies in the Netherlands. One team in Amstelveen, in English and Dutch.

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21%Dutch standard VAT rate, normally paid to customs at import
EUR 0import VAT paid at the border with an Article 23 licence
1 teamfor VAT, corporate income tax and group reporting
Our international tax services

Which international tax services does Oakhill provide?

Most clients start with Article 23 and fiscal representation, and add the rest as their Dutch activities grow.

Container terminal seen from above, representing imports into the Netherlands
Import VAT deferment
01 Article 23 licence

Import VAT deferment with an Article 23 licence

The Article 23 licence (artikel 23-vergunning) moves import VAT from customs to your periodic Dutch VAT return, where you report and deduct it at the same time. With full deduction rights, the net amount payable is nil.

A company established outside the Netherlands cannot apply for the licence itself. It needs a Dutch fiscal representative, and that is the role we take on.

Want the application step by step? Read how to apply for an Article 23 licence in the Netherlands.

Example: goods imported per quarterWithout Article 23With Article 23
Customs value of importsEUR 1,000,000EUR 1,000,000
Import VAT at 21%EUR 210,000 paid to customs at importEUR 210,000 reported on the VAT return
Deducted as input VATOn the next VAT return, refund weeks laterOn the same VAT return
Cash tied upUp to EUR 210,000 per quarterNil (with full deduction rights)

Illustrative figures based on the Dutch standard VAT rate of 21%. Your position depends on your goods, rates and deduction rights.

Glass facade with a repeating geometric pattern
Fiscal representation
02 General fiscal representative

Oakhill as your general fiscal representative in the Netherlands

A general fiscal representative handles all Dutch VAT obligations of a foreign company registered for VAT in the Netherlands under its own VAT number. The representative is established in the Netherlands, provides financial security for the VAT to the Dutch Tax Administration, and is the point of contact for the Belastingdienst.

VAT number and EORI

Registration of your company for Dutch VAT and customs.

Appointment and security

We are appointed as your representative and arrange the required security, such as a bank guarantee.

Article 23 application

We apply for the licence in your name and report your imports under it.

VAT returns and EC Sales Lists

Monthly or quarterly returns and ICP declarations, filed on time.

Input VAT recovery

Dutch VAT on warehousing, logistics and other costs, reclaimed through your return.

Coordination with your customs broker

Your broker declares imports under the licence; we keep customs and VAT data aligned.

Who uses a general fiscal representative?

  • Non-EU manufacturers importing via Rotterdam or Schiphol
  • UK companies that lost easy EU access after Brexit
  • Companies holding stock in a Dutch warehouse
  • E-commerce brands selling B2B or B2C from Dutch stock

General or limited representation?

Limited fiscal representation only covers import followed by an onward B2B supply to another EU country. Do you sell locally, hold stock or recover Dutch input VAT? Then general representation fits. Compare both in our guides on general fiscal representatives and limited fiscal representatives.

03 Dutch VAT compliance

Dutch VAT compliance for foreign companies

Whether or not you need a fiscal representative, Dutch VAT has to be filed correctly and on time. We take over the full cycle, from registration to the yearly reconciliation of your VAT accounts.

VAT registration

Dutch VAT numbers for EU and non-EU businesses, including the right registration route.

VAT returns and ICP

Periodic returns and EC Sales Lists for intra-EU supplies.

OSS for e-commerce

One Stop Shop registration and returns for cross-border B2C sales. See our OSS guide.

VAT refunds for non-EU businesses

Since the second quarter of 2026 these requests can only be filed digitally. We file them for you.

VAT review of your supply chain

A check that invoices, Incoterms and goods flows match your VAT reporting.

Customs changes

What the EU customs reform means for your imports. Read EU customs reform 2026.

Curved blue glass office building
Corporate income tax
04 Corporate income tax

Corporate income tax for Dutch BVs and branches

Dutch corporate income tax (vennootschapsbelasting) applies to every Dutch BV and to foreign companies with a permanent establishment in the Netherlands.

We prepare and file the returns, manage provisional assessments and prepare the annual accounts, so your Dutch entity fits cleanly into the group.

Returns and provisional assessments

Annual corporate income tax returns, with provisional assessments kept in line with actual profit.

Annual accounts and KVK filing

Preparation of the annual accounts and digital filing with the Chamber of Commerce.

Participation exemption

Structuring qualifying shareholdings so dividends and capital gains can stay exempt.

Fiscal unity

Grouping Dutch entities where it lowers tax or simplifies filing.

Branch or subsidiary

The tax side of choosing between a Dutch branch and a BV. Read branch or subsidiary.

Bookkeeping in Exact Online

Where needed, we keep the Dutch books that the returns are built on.

Abstract blue globe of light, representing international group reporting
Group reporting
05 International reporting

Pillar Two and country-by-country reporting

International groups with a Dutch entity have reporting duties that run through Dutch government portals. We prepare and file them for the Dutch entity, in line with the group’s own reporting.

06 Corporate secretarial and portal access

Corporate secretarial support and Dutch portal access

Many Dutch filings require eHerkenning, the Dutch business login, which foreign directors often cannot obtain. With chain authorisation (ketenmachtiging) we file through our own access, and we keep the statutory side of your Dutch entity in order.

Filing without your own login

Chain authorisation through our eHerkenning. Read eHerkenning for foreign companies.

Corporate secretary

Registers, minutes and KVK filings for your Dutch BV. See corporate secretary services.

Legalisation of documents

Support with legalising and apostilling corporate documents for use abroad.

Substance

What the Dutch tax authorities expect from a foreign-owned entity. Read Dutch substance requirements.

How we work

How does working with Oakhill work?

  1. Free assessmentA short call about your goods flows, entities and where the Netherlands fits.
  2. ProposalThe registrations, licences and filings you need, with a clear scope and fee.
  3. SetupVAT registration, fiscal representation, Article 23 licence and portal access, arranged for you.
  4. Ongoing complianceReturns and filings every period, with one point of contact who knows your file.
Your team

Who will you work with?

Your intake is with one of Oakhill’s two managing directors, not a call centre. 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

Can a foreign company apply for an Article 23 licence itself?

No. A company established outside the Netherlands needs a Dutch fiscal representative to obtain and use the Article 23 licence. Oakhill applies for the licence as your representative.

Do I need a fiscal representative just to register for Dutch VAT?

Not always. Many non-EU companies can register for Dutch VAT directly. A fiscal representative becomes necessary to use Article 23, and in some specific situations such as certain distance sales.

What is the difference between general and limited fiscal representation?

Limited fiscal representation covers import followed by an onward B2B supply to another EU country. General fiscal representation covers all your Dutch VAT activities under your own Dutch VAT number, such as local sales, warehouse stock and input VAT recovery.

Can I use a Dutch Article 23 licence for goods cleared in another EU country?

No. The deferment applies to goods released for free circulation in the Netherlands, so the goods need to be cleared through Dutch customs.

Do you also file corporate income tax for a branch of a foreign company?

Yes. A foreign company with a permanent establishment in the Netherlands files Dutch corporate income tax on the profit of that branch. We prepare and file those returns, as we do for Dutch BVs.

Can you file Dutch returns without us having eHerkenning?

Yes. With chain authorisation we file through our own eHerkenning on your behalf. Your company signs the authorisation once and does not need its own Dutch login.

Free assessment

Doing business in the Netherlands from abroad?

Tell us what you import, which entities you have and where your customers are. We will tell you which registrations, licences and filings you need.

Book a free assessment