Guide · Tax & Incentives

E-commerce from Türkiye to the EU: VAT, OSS/IOSS and GDPR checklist

The three compliance layers of selling online to consumers in the EU: VAT registrations (OSS/IOSS), GDPR and consumer rules. A market-entry checklist for Turkish e-commerce companies.

07 July 20264 dk okumaBy Mehmet Köksal · Tax & Incentives
Köksal Attorney Partnership — international desks, global network and GGI work
Summary · At a glance
  • For imported consignments of up to €150, IOSS consolidates VAT collection at the point of sale.
  • In sales through a marketplace, the platform (deemed supplier) most often assumes the VAT.
  • A GDPR representative and a cookie/consent layer establish the data side of selling into the EU.
  • Country-specific obligations (e.g. Germany's packaging registration) should be added to the checklist.

The three-layer compliance model

Selling from Türkiye to consumers in the EU requires managing three separate compliance layers at the same time: tax (VAT and customs), data (GDPR and e-privacy) and consumer (distance selling and return rules). If one of the layers is missing, the result is either cost (double VAT, penalties) or lost sales (cart abandonment, platform sanctions).

Practical guidance

If the IOSS number is not entered correctly into the shipment data, your customer pays VAT a second time at the door — a wave of returns and complaints becomes inevitable. Test your logistics integration.

Enter the EU market in compliance

From tax registrations to sales copy, our International E-Commerce Focus Area sets up your market entry in a single plan.

International e-commerce advisory

The tax layer: IOSS, OSS and deemed supplier

The EU’s e-commerce VAT package has removed the low-value consignment exemption: every imported B2C consignment is subject to VAT. For consignments up to €150, IOSS registration lets you collect VAT at the point of sale, pay it with a single return, and speeds up customs clearance. Note: the customs-duty relief for consignments up to €150 was abolished on 1 July 2026 (Council Regulation (EU) 2026/382); until 1 July 2028 a flat customs duty of €3 per item applies to those consignments. The €150 IOSS threshold for VAT is unchanged. If you hold stock within the EU (e.g. a fulfilment warehouse), local registration in the warehouse country plus OSS for sales to other countries comes into play. For sales through a marketplace, in many scenarios the platform is the party liable for VAT (deemed supplier) — but this affects your pricing and invoicing flow; it does not exempt you from registration.

The data layer: GDPR

Selling to customers in the EU makes GDPR directly applicable: an EU representative under Art. 27, a GDPR-compliant information notice and cookie/consent layer, marketing permissions, and transfer safeguards (standard contractual clauses) for the data flow to your systems in Türkiye. Your KVKK (Turkish Personal Data Protection Law) compliance provides a foundation; however, the gaps with GDPR must be closed.

The consumer layer: distance selling and returns

Under EU rules, the consumer generally has a 14-day right of withdrawal without giving reasons; this period is extended if the prior information is incomplete. Return costs, delivery times and warranty terms must be presented in texts that comply with the language and rules of the target country. Country-specific obligations such as packaging registration (LUCID) for Germany must be added to the checklist.

Market-entry checklist

1) Tax registrations according to the sales model (IOSS/OSS/local); 2) IOSS data-integration testing with the logistics provider; 3) GDPR representative and set of texts; 4) multilingual sales and return policies; 5) marketplace verification documents; 6) country-specific registrations. These six steps must be completed before the first order.

The platform layer: the rules of selling on a marketplace

Selling on EU marketplaces adds a fourth layer: platform compliance. The DSA imposes a seller-verification (KYBC) obligation on marketplaces — the documents evidencing your identity, registry and bank details must be up to date and consistent; inconsistency is the most common technical reason for account suspension. In the event of suspension, the platform is obliged to give reasons and provide an appeal route; the appeal file must be built with orderly evidence and correspondence. On the Turkish side, the ETBİS registration and İYS approval regime of Law No. 6563 (Turkish E-Commerce Law) continue to bind your domestic operation — the two regimes must be combined into a single compliance plan. If you sell connected products, the data-access rules of the Data Act also touch your product contracts.

As you scale: structural decisions

Moving from a few hundred orders a month to thousands brings three structural questions to the fore. Warehousing/fulfilment: holding stock within the EU shortens delivery times but creates a local VAT registration in the warehouse country. Product-safety (GPSR) duties and, for connected products, Data Act duties are independent of the warehouse: they apply to anyone placing the product on the EU market. Incorporation: beyond a certain turnover and return volume, an EU company (usually a GmbH in Germany) becomes advantageous in terms of tax, platform trust and logistics contracts. Brand protection: as sales grow, so does the risk of counterfeiting; EU trademark registration and platform complaint mechanisms must be part of your intellectual property strategy. Each of these decisions is modelled together in the single work plan of our International E-Commerce Focus Area.

The Köksal approach

With our tax team we handle the VAT registrations, with our data team the GDPR/KVKK layer, and with our Germany and United Kingdom Regional Desks the local obligations — all closed off in a single checklist. From marketplace suspension appeals to fulfilment contracts, we build your operation to be resilient at scale.

Conclusion

E-commerce to the EU is a scalable revenue channel when set up well, and an operation that generates returns and penalties when set up badly. Companies that build the tax, data, consumer and platform layers into a single plan see the difference in the first quarter — and do not have to rebuild the structure as they grow.

This content is intended for general information purposes only and does not constitute legal advice. For an assessment specific to your situation, please get in touch with our team.
Mehmet Köksal

Author

Mehmet Köksal

Founder and Managing Partner

Combining legal practice with academic work since 1987, Prof. Dr. iur. Mehmet Köksal advises on corporate and commercial law, contracts, employment, foreign direct investment, ESG and supply-chain due diligence, dispute resolution, consumer law and family law.

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IOSS manages, with a single registration, the VAT on sales of up to €150 shipped from outside the EU; OSS, on the other hand, is for cross-border sales made from stock within the EU.

A local VAT registration is required in the country where you hold stock; OSS covers sales to other Member States. The fulfilment model determines your tax structure.

No; this is general information. Contact our team for your model.

Knowledge Centre

Enter the EU market in compliance

From tax registrations to sales copy, our International E-Commerce Focus Area sets up your market entry in a single plan.