New VAT registrations: e-commerce continues to drive demand from foreign operators

The data published by the VAT Registration Observatory offer some food for thought on the trends and possible developments in the tax system from a supranational perspective. If we look at the ‘historical’ data for the year 2025, we can see that the registration of tax accounts by non-residents related almost entirely (91.8 per cent) to the trade sector, both wholesale and retail. Although the figure is aggregated, data from the Ministry of Economy and Finance (MEF) suggest that, over the last five years, these have mostly been e-commerce operators, whilst new tax registrations in traditional retail were in the minority.

This, however, appears to be at odds with the objective pursued by the EU through the extension of the single-window scheme (OSS in particular), implemented as part of the first package of measures for 2019–2021, which – specifically for distance sales via the internet (online shops and marketplaces) and cross-border services to private individuals within the EU – aimed to reduce the need for multiple VAT registrations, making it possible to apply the tax due in the various Member States without having to obtain a local VAT number.

The reason for these figures remaining (still) so high is likely to be precisely because the reform launched with the extension of the ‘One-stop shop’ scheme (OSS) – which was accompanied by the IOSS system for sales of imported goods to private individuals – has not yet been fully implemented. In the meantime, however, the services offered by major logistics operators have increased exponentially; by guaranteeing minimum delivery times, they inevitably require the presence of ‘local’ warehouses for the storage of goods to be delivered to customers’ homes. From a VAT perspective, this involves transfers of stock between Member States, resulting in the need to hold VAT registrations in the Member States concerned (both of departure and arrival). The same applies to goods which, having been brought into the EU from third countries, are then transported to other Member States.

Furthermore, a local VAT registration number is required for certain transactions that cannot be handled under the OSS scheme. This applies to sales involving installation and assembly in the purchaser’s EU Member State, or to domestic sales within a single Member State to private individuals. Not to mention that VAT paid in other countries on purchases of goods and services is not deductible from the VAT due under the OSS scheme and may therefore require a local VAT number in order to claim the deduction.

Things are set to change in the future. The ViDa package for VAT in the digital age should, in fact, reduce the need for multiple identification numbers over the coming years (2027–2028). Under the Single VAT Registration system, the scope of the OSS will be extended to cover transactions that are currently excluded, and the number of cases where a VAT number from another country is required for the transfer of goods for storage should decrease.