H
Holdwise
Situations

Your fiscal representative is ending the service. Take the licence in-house.

The letter is short: the representation agreement ends, wind-down in ninety days. Fiscal representatives trim their books — risk policies tighten, guarantee capacity fills up, sectors fall out of appetite — and the importer on the receiving end loses the Article 23 deferment that kept import VAT out of every shipment's cash flow.

The dependency was the design flaw: the licence lived in the representative's name. The permanent version puts it in yours — a Dutch BV holding Article 23, the EORI number and the VAT position directly, with a structure that answers to your risk policy alone.

21%import VAT back at the border meanwhile
Own namewhere the licence belongs
1xthis transition, done permanently

Bridge the gap, then close it

Two moves run in parallel. Short term: a limited representation arrangement for shipments in transit keeps goods moving through the wind-down. Structurally: the Dutch BV incorporates, activates its VAT number and applies for its own Article 23 licence — typically some weeks after VAT activation — so the flow lands in your own structure before the old agreement closes.

What in-house changes beyond the licence

The BV becomes the importer of record with its own EORI number, invoices European customers as a European supplier, and carries the compliance roles a representative never held — responsible person, EPR, the contracts. Guarantee and audit conversations happen once, with your own advisors, instead of annually with a provider's risk committee. The dependency ends where the structure begins: the full route.

Frequently asked questions

Why do fiscal representatives terminate clients?

Risk policies tighten, bank-guarantee capacity fills, sectors fall out of appetite, and books get trimmed. The termination usually reflects the provider's portfolio, and it lands on the importer as lost Article 23 deferment.

What happens to import VAT during the gap?

Import VAT falls due at the border on each shipment until a new arrangement stands — cash out at clearance, recovered later through the VAT process. A limited representation bridge for goods in transit keeps the gap short while the own licence is arranged.

How does the own Article 23 licence work?

A business established in the Netherlands — your Dutch BV — holds the licence in its own name after VAT activation, and import VAT moves permanently into the periodic VAT return, where the same filing deducts it.

Is the own-BV route heavier than representation?

It carries a real structure: administration, filings, substance. In return the licence, the customer relationships and the compliance roles answer to your risk policy alone — the trade most structural importers make once and keep.

Hold the licence in your own name

Holdwise incorporates Dutch BVs for importers taking Article 23 in-house, and arranges the VAT, EORI and licence sequence around your wind-down clock.

Start your Dutch BV

Sources

  1. Belastingdienst, Article 23 import VAT deferment licence.
  2. Holdwise, fiscal representation: the two routes.

Last reviewed 13 August 2026.