Second VAT Number in the EU: When You Need One (2026)

Most EU businesses need exactly one VAT number: the one issued by the member state where they are established. But international VAT registration is a real obligation for a large number of them. Hold stock in a warehouse abroad and you may owe VAT there. Run services through a fixed establishment and the place of supply may move. Ship goods to a business customer without their VAT number and your "exempt" supply quietly becomes a taxable domestic one.

This guide works through each trigger, quotes the Directive directly rather than paraphrasing it, and ends with what changes from 2028. Where a rule is set nationally rather than in Brussels, it says so - because a page that pretends one number applies across the EU is worse than no page.

The short answer

The table is a starting point, not a decision. The two rows in bold are where most surprises happen, and they are the subject of sections 3 and 4.

1. Every taxable person registers where they are established

Article 9 defines a taxable person as anyone who independently carries out, in any place, an economic activity, whatever its purpose or results. If you meet that definition you are taxable, and the baseline obligation follows from it: you are identified for VAT in the member state where you are established.

Article 214(1) puts the mechanics in place. Member States must ensure that every taxable person - with the exception of those covered by Article 9(2) - who carries out supplies in respect of which VAT is deductible is identified by an individual number. That exemption clause matters: a business that only makes supplies where VAT is payable solely by the customer is not caught by 214(1)(a).

Everything below is an exception, an extension, or an alternative to that one number.

2. The small-business threshold is national, and capped

There is no EU-wide registration threshold. Each member state sets its own, and Article 284(1) caps it:

"Member States may exempt the supply of goods and services made within their territory by taxable persons who are established in that territory and whose Member State annual turnover, attributable to such supplies, does not exceed the threshold fixed by those Member States for the application of this exemption. That threshold shall be no higher than EUR 85 000 or the equivalent in national currency."

Article 284(1)

Read that carefully. The exemption covers supplies made within that member state by a business established there. It is not a general small-business exemption you can carry with you into another country.

Article 284(2) lets one member state extend its exemption to supplies made by a business established elsewhere, but only if two conditions are both met:

• the Union annual turnover of that taxable person does not exceed EUR 100 000, and
• the value of the supplies in the member state where the business is not established does not exceed the threshold that state applies to its own businesses.

Both legs, and both ceilings. The EUR 85 000 figure is the national cap; the EUR 100 000 figure is a separate Union-wide turnover limit for this cross-border extension. They are not the same number and should not be quoted interchangeably.

3. Holding stock abroad: the trigger most sellers miss

Put your own goods in a warehouse in another member state - Amazon FBA, a 3PL, or your own - and the position changes fundamentally. Those goods are no longer sitting in your home state. When you sell them, you are making a domestic supply in the state where they physically sat when the supply began.

No EU scheme removes that obligation. The One Stop Shop handles distance sales of goods dispatched from your establishment to consumers elsewhere; it does not handle selling goods that are already sitting in the destination country. This is the single most common reason an online seller ends up needing a local VAT number they did not plan for.

The acquisition side has its own rules. Article 33 covers intra-Community acquisitions of goods by a taxable person or non-taxable legal person who is not eligible for the small-enterprise exemption, and it sets a floor rather than a ceiling:

"...during the current calendar year, the total value of intra-Community acquisitions of goods does not exceed a threshold which the Member States shall determine but which may not be less than EUR 10 000 or the equivalent in national currency."

Article 33(2)(a)

Which state is treated as the place of that acquisition? Article 41 answers it in an unusual way:

"The place of an intra-Community acquisition of goods as referred to in Article 2(1)(b)(i) shall be deemed to be within the territory of the Member State which issued the VAT identification number under which the person acquiring the goods made the acquisition, unless the person acquiring the goods establishes that VAT has been applied to that acquisition in accordance with Article 40."

Article 41

So the acquiring state is the one whose VAT number you used on the acquisition - not necessarily the state the goods physically passed through. That has practical consequences when a warehouse moves your stock between member states, or when a freight forwarder acquires on your behalf.

4. Services and the fixed establishment test

For services, the place of supply starts from two articles. Article 44 governs B2B: the place of supply is where the customer is established - but where the services go to a fixed establishment of the customer located elsewhere, it is where that fixed establishment is. Article 45 does the mirror image for consumers: the place of supply is where the supplier is established, or where the supplier's fixed establishment is if the supply comes from one.

Article 43 is the provision that decides whether you have a fixed establishment, and it is worth reading as a whole rather than quoting selectively - it turns on the resources your business makes available to that establishment, not merely on whether invoices are issued from it.

The practical consequence: a single registration plus the Union OSS will normally cover B2C services across the Union, provided you are not making those supplies from a fixed establishment in the destination state. The moment you are, you need to be identified there.

5. When you do not need a number: reverse charge

Article 193 states the default: VAT is payable by the taxable person making the supply, "except where it is payable by another person in the cases referred to in Articles 194 to 199b and Article 202."

For a supplier established elsewhere, Article 194(1) allows member states to provide that VAT becomes payable by the person receiving the supply rather than the supplier.

Article 196 does this for services:

"VAT shall be payable by any taxable person, or non-taxable legal person identified for VAT purposes, to whom the services referred to in Article 44 are supplied, if the services are supplied by a taxable person not established within the territory of the Member State."

Article 196

Note what it points at: Article 196 charges the customer precisely because the supply falls under Article 44 - the B2B services place-of-supply rule. Reverse charge and the B2B place-of-supply rule are the same mechanism seen from two ends.

For goods, Article 197 requires all three of these:

• the transaction is a supply carried out in accordance with the conditions laid down in Article 141;
• the recipient is another taxable person, or a non-taxable legal person, identified for VAT purposes in the member state in which the supply is carried out;
• the invoice from the non-established supplier follows the invoicing formalities of Chapter 3, Sections 3 to 5.

If any one of the three fails, reverse charge is not available and you are back to needing an identification number in that state. Article 202 is the related self-assessment rule that applies when goods leave the arrangements or situations listed in Articles 156 to 161 and Article 160 - the inward-processing and similar regimes.

6. Intra-Community supply of goods: Article 138 as it now reads

Most B2B goods shipments are exempt from VAT. Article 138 grants that exemption, and it is narrower than it is often described. In its current form, a supply of goods dispatched or transported to a destination outside the supplier's own member state but within the Community is exempt only where both of these are met:

• (a) the goods are supplied to another taxable person, or to a non-taxable legal person acting as such, in a member state other than that in which the dispatch or transport begins; and
• (b) that recipient is identified for VAT purposes in a member state other than that in which dispatch begins, and has indicated this VAT identification number to the supplier.

Condition (b) is where a lot of invoices go wrong. Since 2020 it is not a formality. If the customer never gave you a VAT number from another member state, or the number is not valid, you have not met condition (b) - and the supply is a taxable domestic supply in your own member state, not an exempt one. Check the number on the EC VIES portal and keep the evidence.

Article 138(1a) adds a reporting condition that is easy to miss: the exemption does not apply where the supplier has not submitted the recapitulative statement required by Articles 262 and 263, or where that statement does not correctly set out the supply as required by Article 264.

And Article 139 removes the exemption in two situations worth noting - it does not apply to supplies made by businesses covered by the small-enterprise exemption under Article 284, nor to supplies to recipients whose own intra-Community acquisitions are outside the scope of VAT under Article 3(1).

7. Businesses established outside the EU

For a business with no EU establishment, the EU-wide threshold does not do the work it does for an EU business. Non-established suppliers are governed by Article 33 (goods) and Article 58 (services), which apply once activity reaches the Union, and a fiscal representative is normally a condition of the authority accepting a VAT registration. The precise requirement is set nationally, so the tax authority of the member state you are registering in is the place to confirm it.

If you dispatch goods from outside the EU directly to consumers, and none of them exceed EUR 150, the IOSS can handle the VAT without any local registration. If you are holding stock inside the EU, the position from section 3 applies to you in full.

8. What changes from 2028

Council Directive (EU) 2025/516 - the package commonly called ViDA - amends the VAT Directive. The amendments in its Article 3 apply from 1 July 2028. Three of them bear directly on everything above.

• The Union OSS scope widens. ViDA extends the Union scheme to cover domestic business-to-consumer supplies of goods in the Union made by a taxable person not established in that member state. That is the section 3 problem - stock sitting in a warehouse - addressed at the scheme level rather than by registration.
• Reverse charge becomes mandatory in a defined case. Where a supplier is neither established nor identified for VAT purposes in the member state where VAT is due, the recipient accounts for it, rather than leaving member states the option.
• A new scheme covers transfers of own goods. ViDA provides a special scheme for distance sales of a business's own goods - the cross-border movement of stock between member states - so that moving inventory is no longer, in itself, something that drags in a second registration.

Other ViDA measures apply on different dates from 1 January 2027 and through the 2030s. If your planning horizon crosses those dates, read the amending act rather than this summary - the transitional structure is genuinely intricate.

9. A decision path

1. Do you physically hold your own goods in another member state? If yes, plan on registering there. Section 3.
2. If not, are you making supplies from a fixed establishment there? If yes, register. Section 4.
3. Otherwise, is the supply of services? B2B generally follows the customer's member state and can be handled by reverse charge; B2C generally follows yours and can be declared through the Union OSS.
4. Is it goods going to a business customer in another member state? Check you have their VAT number in writing and that it validates. Section 6.
5. Still unsure? Look at where the goods sat when the dispatch began, not where the customer is. That single question resolves most cases.

10. What registering actually involves

Beyond the threshold question, a second registration brings recurring obligations: periodic returns in that member state, records in its language, and a working contact there. A fiscal representative is normally required for a non-EU business. None of that is unusual, but it is why "just register everywhere" is rarely the right advice - the right answer is usually one registration plus a scheme.

Frequently asked questions

Does the OSS replace a second VAT number?

No. The Union OSS is a reporting mechanism for cross-border B2C distance sales made from your establishment. It does not cover domestic supplies of goods you hold locally, which is the case that actually triggers a second registration.

Is there one EU-wide registration threshold?

No. Each member state sets its own under Article 284(1), capped at EUR 85 000. The EUR 10 000 figure that circulates is different in kind: Article 59c sets the threshold at which the identification obligations in Article 33 and Article 58 stop applying for the Union OSS. Two different rules, two different articles.

Do I need a second number to sell B2B across the EU?

Usually not. For services, Article 44 places the supply where the customer is established, and Article 196 moves the VAT to the customer. For goods, Article 138 exempts the supply outright provided both conditions are met - and condition (b) means you must hold their VAT number.

My customer gave me a VAT number that does not validate. What now?

Treat the supply as a taxable domestic supply in your own member state. Condition (b) of Article 138 is not satisfied, so there is no intra-Community exemption to rely on. Ask the customer to correct it and re-verify on VIES if you can.

Does holding stock abroad trigger registration even if I sell only B2B?

Generally yes. The trigger is the location of the goods when the supply begins, not who the customer is. Selling B2B from foreign stock is a domestic supply in that state, and reverse charge does not rescue it - reverse charge under Article 197 addresses intra-Community supply chains, not domestic supplies.

Will all of this change in 2028?

Partly. ViDA widens the Union OSS and introduces a scheme for transfers of own goods from 1 July 2028, which should reduce the number of second registrations for cross-border sellers. It does not remove the obligation to be identified where you are established.

Related guides

Sources

Council Directive 2006/112/EC, consolidated text as at 1 January 2025, Title II Chapter I (place of supply), Title VI Chapters 2-4 (intra-Community supplies and acquisitions), Title IX (exemptions), Title XI Chapters 1 and 3 (identification and invoicing), Title XIII (special regimes). Council Directive (EU) 2025/516, Article 3 and recitals 2 to 4. National thresholds are set by each member state; confirm the current figure with the relevant authority before relying on it.