Stop prefinancing import VAT: a fiscal representative or your own Dutch company
You import goods from outside the EU and pay import VAT at the border every month. The refund comes weeks later. The Dutch Article 23 licence ends that payment. This page compares the two ways to use it: through a fiscal representative, or through your own Dutch company.
Ask about your situationA Dutch fiscal representative is enough to stop prefinancing import VAT. With the Dutch Article 23 licence, the import VAT is reported in the VAT return and deducted in the same return. At the border you pay only the customs duty, where it applies.
Your own Dutch company, a BV, is the second way. It applies for the licence in its own name, is the importer on the customs declarations and sells to your buyers from the Netherlands. It fits when you import every month, keep stock in the Netherlands, or want your contracts, bank account and registrations in a European company of your own.
Both ways work for a company that imports ten containers a month and sells to buyers in several EU countries. The comparison below shows the differences, so you can choose.
Why you prefinance import VAT today
Import VAT is due when customs accepts the import declaration. Under the standard rule, the importer pays it at the border and deducts it later in its VAT return. The deduction is for the company in whose name the goods were declared and that uses them for its own taxed sales.
For a company that imports every month, the payment and the refund repeat every month. With monthly VAT returns, one to two months of import VAT are tied up at any moment. The more you import, the larger that amount.
What the Article 23 licence does
Article 23 of the Dutch VAT Act (Wet op de omzetbelasting 1968) allows the Dutch tax authority, the Belastingdienst, to grant a licence for import VAT. With the licence, the import VAT is reported in the periodic VAT return and deducted in the same return. The customs declaration shows the licence, and the VAT payment at the border ends. Customs duty, where it applies, is still paid at the border.
The Belastingdienst grants the licence to businesses that live in or are established in the Netherlands, that import regularly, that keep separate records showing the import VAT, and that file monthly or quarterly VAT returns. A company established outside the Netherlands uses the licence through a Dutch fiscal representative.
Stock in a Dutch warehouse counts as storage. A company with only storage in the Netherlands is a foreign business for VAT.
Way one: a Dutch fiscal representative
A fiscal representative is a company established in the Netherlands with a licence from the Belastingdienst to act for foreign businesses. There are two licences. Both work with Article 23.
| Limited licence (beperkte vergunning) | General licence (algemene vergunning) | |
|---|---|---|
| What it is for | Imports from outside the EU and the sales that follow: supplies to business buyers in other EU countries, exports, and sales to Dutch business buyers under reverse charge. Distance sales to consumers need the general licence or your own company. | All your Dutch VAT: imports, sales in the Netherlands and purchases from other EU countries. |
| Article 23 | One licence of the representative, used for all its clients, under its own VAT number. | A separate Article 23 licence for you, linked to your own Dutch VAT number. |
| Dutch VAT number | You work under the VAT number of the representative. | You receive your own Dutch VAT number. |
| Security for the Belastingdienst | Given by the representative: 5% of the average monthly VAT, at least €5,000, up to €100,000 for bulk goods, semi-finished products and means of production, or up to €500,000 for consumer goods. The representative is liable for all the VAT. | Given by the representative, with the same formula. Its liability per calendar year is limited to the security. |
For goods that you import into the Netherlands and sell to businesses in other EU countries, the limited licence fits. The representative takes on a security and a liability for your VAT, so it checks your goods, your buyers and your records before it starts.
Way two: your own Dutch company
Your own Dutch company, a BV, is established in the Netherlands. It registers for VAT in its own name and applies for its own Article 23 licence with the form Aanvraag Vergunning artikel 23. The Belastingdienst advises applying well before the first import.
The company is also the importer. It declares the goods in its own name with its own customs number, the EORI number, or through a customs agent that acts in its name. A company from outside the EU uses an indirect customs representative for every declaration, because EU customs law requires the declarant to be established in the EU (Union Customs Code, Article 170).
For VAT, EU law places a business where its central administration is carried out. It looks at where the essential management decisions are taken, where the registered office is and where the management meets; when these differ, the place of the essential management decisions counts (Implementing Regulation (EU) 282/2011, Article 10). Decide early who manages the BV and where.
The two ways side by side
| Fiscal representative | Your own Dutch company | |
|---|---|---|
| Import VAT at the border | Ends, through the Article 23 licence of the representative or a licence for you | Ends, through your own Article 23 licence |
| What you set up | An agreement with a licensed representative | A Dutch BV, set up by power of attorney, usually within one week once all documents are complete |
| Importer for customs | An indirect customs representative in the EU | Your own company, with its own EORI number |
| Sales to other EU countries | 0% VAT, reported by the representative | 0% VAT, in your own VAT return and recapitulative statement (ICP listing) |
| Contracts and bank account | In your company abroad | In a European company of your own |
| Food registration with the NVWA | For companies in the Dutch trade register (KVK) | Your own company, after its KVK registration |
| Profit on the European sales | Taxed in your home country | The Dutch company earns a margin on its sales and pays Dutch corporate tax: 19% on the first €200,000 of profit, 25.8% above |
| Suits | A first year, a test market, goods that pass through to buyers in other countries | Monthly imports, stock in the Netherlands, European buyers who want a European seller |
Worked example: ten containers of nuts a month from Serbia
A Serbian company imports nuts and dried fruit through Rotterdam, about ten containers a month. It sells to buyers in Poland, Italy and the Netherlands. Suppose each container has a customs value of €50,000.
Customs duty. Under the Stabilisation and Association Agreement between the EU and Serbia, the EU abolished its duties on most agricultural products of Serbian origin. With a valid proof of origin, most nuts and dried fruit enter at 0% duty. The proof is an EUR.1 certificate, or an origin declaration on the invoice: any exporter can make one for a consignment up to €6,000, and an approved exporter for any value. A full container usually comes with an EUR.1 certificate. Check the exact product code in the EU tariff database (TARIC).
Import VAT. Dutch VAT on food is 9%, so the import VAT is about €4,500 per container and €45,000 a month. Paid at the border, that is €45,000 every month, refunded through a later VAT return. With the Article 23 licence, the same €45,000 is reported and deducted in the VAT return of the month itself.
Sales. The sales to Poland and Italy are intra-EU supplies at 0% VAT: the buyer’s VAT number checked and on the invoice, proof that the goods went to that country, and the sale in the recapitulative statement, the ICP listing. Sales to Dutch business buyers are taxed at 9% Dutch VAT, or reverse-charged to the buyer under a limited fiscal representative.
Food rules. A company that imports food registers with the Dutch food and consumer product safety authority (NVWA), after its registration with the Chamber of Commerce (KVK). It must be able to trace its suppliers and its buyers (General Food Law, Regulation (EC) 178/2002, Article 18). Check the EU list of foods with increased border checks for your product and its origin (Implementing Regulation (EU) 2019/1793, as amended by Implementing Regulation (EU) 2026/1206).
Sources: Belastingdienst, reverse-charge mechanism on import (Article 23); Besluit fiscale vertegenwoordiging of 19 December 2022 (Staatscourant 2022, 32161); Union Customs Code, Regulation (EU) 952/2013, Articles 18 and 170; Implementing Regulation (EU) 282/2011, Article 10; Regulation (EU) 2026/2108, which replaces the Union Customs Code from 21 September 2027; Stabilisation and Association Agreement between the EU and Serbia, Article 26; Regulation (EC) 178/2002; Implementing Regulations (EU) 2019/1793 and 2026/1206. Checked on 25 September 2026.
Who does what
Holdwise sets up and manages the Dutch company, or prepares the file for a licensed fiscal representative. Customs agents and warehouses do the physical work. You keep one contact.
Your company
- Your goods, your buyers and your prices
- The proof of origin from your exporter: EUR.1 or invoice declaration
- The product codes and values for every shipment
- The choice between the two ways
The Dutch base
- Sets up the Dutch BV by power of attorney, with the notary
- VAT number, EORI customs number and the Article 23 application
- Monthly bookkeeping, VAT returns and the ICP listing
- The NVWA registration when you import food
- One point of contact for customs, bank and representative
Customs, representation, storage
- Fiscal representative with a limited or a general licence
- Customs agent for the declarations in Rotterdam
- Business address in the Netherlands
- Warehouse and transport to your buyers
Step by step
From your first question to the first import with the licence.
- Your volumes. You send the products, the monthly value, the countries of your buyers and the warehouse you plan to use. Holdwise answers in writing which of the two ways fits and what it involves.
- The company or the representative. For your own company, the notary sets up the BV by power of attorney, usually within one week once all documents are complete. For representation, Holdwise prepares the file for a licensed representative.
- The numbers. VAT number, EORI customs number and, for food, the NVWA registration.
- The licence. The Article 23 application is sent to the Belastingdienst well before the first import.
- The first import. Once the Belastingdienst has granted the licence, the customs agent declares the goods with it. The import VAT is reported in the VAT return of that month and deducted in the same return.
- Every month. Bookkeeping, the VAT return and the ICP listing for your sales to other EU countries.
Related guides
More on import VAT, customs and selling from the Netherlands.
Common questions
Ask about your own situation
Tell us what you make or sell, where your company is and which countries you want to sell in. You get a written answer. Where a Dutch company fits, we write down what it would look like and what it costs.
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