In EU VAT, one registration, regular filing, zero surprises.
VAT compliance on B2C sales to the EU: setting up OSS/IOSS registrations, the filing regime, threshold monitoring, marketplace (deemed supplier) scenarios, and warehouse/fulfilment registrations.
The logic of the EU VAT package
The EU's e-commerce VAT reform moved taxation on B2C sales to the consumer's country and eased the resulting administrative burden with two one-stop systems: OSS for intra-EU distance sales, and IOSS for orders up to €150 shipped from outside the EU. The low-value-consignment exemption was abolished; an unregistered sale produces either a surprise tax at the door for the customer or a penalised tax assessment for the seller.
Which registration, in which scenario?
Direct shipment from Türkiye (≤ €150)
IOSS — VAT is collected at the time of sale and fast customs clearance is provided; for a non-EU seller, an intermediary must be appointed.
Stock within the EU (fulfilment/warehouse)
a local VAT registration in the warehouse country + OSS for intra-EU sales; a warehouse in Germany means a German VAT registration.
Sales via a marketplace
in many scenarios the platform assumes the VAT (deemed supplier) — but this does not entirely remove your registration and documentation obligations.
Mixed models
a structure that separates by channel is essential; a wrong mapping produces double taxation or a gap.
Filing regime and documentation discipline
OSS/IOSS registrations are the beginning of the work; filing the monthly/quarterly returns with the correct country breakdown, processing exchange-rate and refund adjustments, and reconciling with sales-channel reports is the core work. Customs and origin: tariff classification and origin planning directly affect delivery cost and speed; on the Türkiye side, the filing and offset regime for the 1% withholding applied to marketplace payments since 2025 is also handled at the same table. The tax side must be designed together with the contract and data layers of your e-commerce operation — our guide offers a complete checklist.
Four common mistakes
Double filing
including in your own OSS return the sales for which the marketplace is the deemed supplier; this produces double VAT and a correction burden.
Warehouse blindness
failing to register locally in the country your fulfilment stock is moved to; the accumulated interest and penalties usually surface at the first audit.
IOSS number leakage
sharing the number without control in shipping processes, which creates the risk of someone else’s sale appearing in your return.
The intermediary relationship
leaving the liability and data-flow provisions of the contract with your IOSS intermediary blank; the filing history is lost when you change intermediary.
The Türkiye layer, and what you get
On the Türkiye side the export exemption (VAT Law No. 3065) and the ETGB regime for micro-exports form a single chain with your EU registrations; if the document flow breaks, the exemption cannot be defended. The tax set-up is directly tied to the health of your marketplace account: the platform reports are the primary source for reconciling your returns. What you get: a channel-to-registration mapping table, the registration application files, a filing workflow document and reconciliation templates. Before you start there is a one-question test: for every sales channel, can you say in a single sentence who declares the VAT, in which country, and under which registration? If not, the set-up is incomplete — and our tax compliance team closes the gap.
We are by your side for OSS / IOSS & EU VAT Registrations
We map your sales channels, set up the correct registration set (including the appointment of an intermediary where necessary), run the filing calendar end-to-end with our accounting team, and perform periodic reconciliation with marketplace reports. For Germany-focused operations, our Germany Desk takes on coordination with local tax advisors.
Other Applications of This Service
Tax Compliance — our other specialised solutions in this area.
Matter Connections
The focus areas, practice areas, desks and legislation connected with this sub-service.
Our Matters in This Service
The anonymised examples of our work that relate to this service.
Cross-border acquisition of a manufacturing facility in Türkiye
End-to-end representation of the buyer in a multi-jurisdictional acquisition, from due diligence to closing.
Review the matter →Investment · GreenfieldStructuring an incentivised manufacturing investment
Management of company formation, the incentive certificate and compliance processes in a greenfield investment.
Review the matter →Dispute · TaxConcluding a tax audit through settlement
In a transfer-pricing-focused audit; representation from the minutes stage through report assessment, and execution of the settlement strategy.
Review the matter →The Team Delivering This Service
With our multilingual team of lawyers, well-versed in Turkish and German law, we are by your side.
Related Publications
Fresh perspectives and guides from the Knowledge Centre.
Even in the deemed supplier scenario, your obligations continue for registration, invoicing/documentation and returns processes; in addition, your channels outside the marketplace (your own site) require a separate setup.
Voluntary disclosure mechanisms significantly reduce penalties in most member states. We quantify the risk by period and by country and build a correction strategy — waiting increases the cost.
As a rule, non-EU sellers register for IOSS through an intermediary established in the EU. The choice of intermediary and the allocation of liability should be made clear by contract.
This threshold is merely the lower limit below which sellers established in a single EU country may sell under their home country’s VAT. A Turkish company with no establishment in the EU is subject to destination-country VAT from the very first sale it makes from a warehouse inside the EU…
OSS / IOSS & EU VAT Registrations — get the right legal support.
Let us identify the right solution together, drawing on our experience in Türkiye and the DACH region.