International Marketplace VAT OSS/IOSS: Technical Reconciliation 2026

Up to date as of 14 May 2026. If you sell on Amazon, Cdiscount, or through your own Shopify storefront to consumers across Europe, the challenge is not simply "apply the customer's country VAT rate". It involves a complete pipeline: determining who is liable — you or the marketplace — exporting transactional data, verifying rates by country and product category, consolidating the quarterly OSS return, and archiving evidence for 10 years. Cabinet Hayot Expertise in Paris has been handling these e-commerce files since the July 2021 reform and works with French DNVBs as well as Amazon FBA sellers active across multiple European warehouses.

Who can register for OSS Union?#

The OSS Union scheme (One Stop Shop) is set out in Article 298 sexdecies F of the French Tax Code (CGI). It is available to taxable persons established in France — or having designated France as their Member State of identification — who make intra-EU distance sales of goods to consumers (B2C) in other Member States. The scheme also covers B2C services supplied to customers in other Member States where the provider is established in the EU.

Registration is made with the DGFiP through the OSS portal. Once registered, the trader files a single quarterly return and makes a single payment covering VAT due in all concerned Member States, without needing local VAT registrations in each country.

The €10,000 threshold: calculation and practical implications#

The threshold triggering the obligation to charge the customer's country VAT rate is set at €10,000 net per year, calculated across all intra-EU B2C distance sales of goods and TBE services (telecommunications, broadcasting, electronic). This threshold is global across all EU destinations — it is not calculated country by country.

Below €10,000, the seller can continue to apply French VAT on its EU B2C sales. Once the threshold is crossed — or if it was crossed in the prior year — the destination country VAT applies. Early registration for OSS before reaching this threshold is possible and is often the preferred approach for businesses scaling cross-border sales.

Excluded from OSS: excise goods, new means of transport, installed goods#

Some categories fall outside the OSS scope: new means of transport, excise goods (alcohol, tobacco, energy products), and goods installed or assembled on site by the supplier. These sales remain subject to local VAT registration in the destination Member State and cannot go through OSS.

Mechanism and access conditions#

The IOSS (Import One Stop Shop) scheme is set out in Article 298 sexdecies G III of the CGI. It allows sellers shipping goods from third countries (China, the US, the UK post-Brexit, etc.) to EU consumers to collect VAT at the point of sale, provided the intrinsic value of the goods does not exceed €150. VAT is remitted monthly through the IOSS portal in the country of identification.

For consignments below €150 without an IOSS number, VAT is collected at the border by customs authorities, generating additional clearance costs, delays, and a degraded customer experience. Above €150, IOSS does not apply: VAT is compulsorily collected at import by customs.

Mandatory fiscal intermediary for non-EU sellers#

A seller established outside the EU wishing to register for IOSS must appoint a fiscal intermediary established within the EU. This intermediary is jointly and severally liable for IOSS VAT payments. This is a formal legal obligation, distinct from simple VAT fiscal representation. Logistics operators often offer this service, but their joint liability requires verifying their solvency and compliance track record before appointment.

IOSS and marketplaces: who handles the filing?#

If you sell through Amazon or another deemed-supplier marketplace, the marketplace handles IOSS for the sales it facilitates. The seller has no IOSS obligation on those sales. However, for direct sales through your own storefront (Shopify, WooCommerce) involving imported goods with a value below €150, the non-EU seller must appoint its own IOSS intermediary.

The rule in force since 1 July 2021#

Since 1 July 2021, Article 256 V of the CGI transposes EU Directive 2017/2455 as amended: in certain cases, the marketplace (Amazon, Cdiscount, Fnac, Allegro, etc.) is deemed to have purchased goods from the third-party seller and resold them to the end consumer. The marketplace becomes the VAT debtor, not the seller.

Two situations trigger this deemed-supplier rule:

• Sales of goods imported from third countries with an intrinsic value ≤ €150, regardless of where the third-party seller is established.
• All goods sales through the marketplace when the third-party seller is established outside the EU, regardless of value.

What this means in practice for FBA sellers#

For an FBA (Fulfillment by Amazon) seller whose stock is in a Polish or German warehouse and who is established outside the EU, Amazon collects and declares VAT on all EU sales through its own OSS number or local VAT registrations. The seller is not liable for VAT on those sales — but must retain evidence that the sale went through the platform to justify the absence of a personal declaration.

For a seller established in France with stock already in France selling into Germany via Amazon, the deemed-supplier rule does not apply to goods already in free circulation in the EU. The French seller collects German VAT (19%) and declares it through OSS.

Direct sales through a proprietary storefront: standard OSS scope#

An e-commerce merchant selling directly through Shopify, PrestaShop, or WooCommerce retains full responsibility for collecting and declaring EU B2C VAT. The seller must configure country-specific tax rates in its platform, connect an automated tax tool (Shopify Tax, Taxually, Avalara), and reconcile sales exports with the quarterly OSS return. Our article on e-commerce accounting mistakes France 2026 covers the most common configuration errors at this stage.

Step 1 — Exporting data from Amazon Seller Central#

The reference report is the "VAT Transactions Report" in Seller Central (menu Reports > Tax > VAT Transactions). It lists each transaction with: ASIN, shipping country, destination country, transaction type (sale, refund, credit note), net amount, applied VAT rate, and VAT amount. Available in CSV by month or quarter.

Key point: the report may not automatically distinguish reduced-rate products (books, food in some countries) from standard-rate goods. If your catalogue includes mixed categories, a line-by-line rate check is essential before consolidation.

Step 2 — Shopify, Stripe or other PSP exports for direct sales#

Shopify generates a "Taxes" report exportable by period. Stripe provides a CSV "Charges" export or via Stripe Tax, which breaks down VAT by country. The trap: Stripe does not know your product's tax category by default. Without explicit configuration (Stripe tax_code), it applies the standard rate — generating declaration errors for reduced-rate or exempt products.

Step 3 — Rate mapping and country-by-country verification#

Each Member State has its own reduced rates, exemptions, and thresholds. Common examples: France applies 5.5% on physical books; Germany applies 7% on physical books and basic foodstuffs; Ireland exempts certain food categories. A single product sold in 10 EU countries may attract different rates in each one, depending on its category.

The mapping must be documented product by product (or category by category) and updated whenever a country modifies its rates. The mapping file is part of the audit trail and must be retained for 10 years.

Step 4 — Quarterly reconciliation table#

The reconciliation table cross-references: VAT collected by country from platform exports, VAT to be declared by country per the rate mapping file, and any corrections (credit notes, returns, rate adjustments). Any gap between VAT collected and VAT to be declared must be traced and explained. An unexplained gap above €50 is a red flag that must be resolved before filing.

In practice at Cabinet Hayot Expertise in Paris, this table is built in a structured XLSX with three tabs: (1) raw data by country and channel, (2) rate control, (3) OSS balance to declare. The file is archived in the client DMS together with the OSS return receipt and payment confirmation.

Step 5 — OSS declaration on the DGFiP portal#

The OSS return is filed at portail.dgfip.finances.gouv.fr, professional space, "Guichet OSS" section. It reports, for each Member State, the net sales amount by applicable VAT rate and the VAT due. The return is in euros; where sales were made in foreign currencies, the ECB exchange rate of the last day of the quarter applies.

Quarterly OSS filing deadlines:

• Q1 (January–March): return and payment no later than 30 April
• Q2 (April–June): return and payment no later than 31 July
• Q3 (July–September): return and payment no later than 31 October
• Q4 (October–December): return and payment no later than 31 January of the following year

A late filing triggers late interest of 0.20% per month (CGI art. 1727), equivalent to 2.4% per year. Penalties of 10% to 80% apply depending on severity (CGI art. 1729). Repeated non-compliance may result in exclusion from the OSS scheme.

Collected VAT vs declared VAT: the core reconciliation check#

The final reconciliation compares total VAT collected as shown in your platform exports against the total declared in the OSS return. Any gap must be documented: it may result from a credit note issued after the quarter close, a customer refund processed in a later quarter, or a retroactively corrected rate error. Unresolved gaps accumulate and become harder to justify in the event of a tax audit.

Accounting integration: 4457x accounts by country#

For bookkeeping purposes, OSS-collected VAT does not sit in the standard account 44571 (French VAT collected). It should be broken down by country into dedicated 4457x sub-accounts: 44572 German OSS VAT, 44573 Spanish OSS VAT, 44574 Italian OSS VAT, etc. This breakdown is essential for reconciliation and for handling a tax review. It is supported by accounting software compatible with multi-country VAT (Pennylane, Sage, Cegid) through configured country-specific VAT journals.

Coordination with customs: EORI number and SAD#

If you import goods from third countries for resale in the EU, you need an EORI number (Economic Operators Registration and Identification) from French customs (douane.gouv.fr). This number appears on the SAD (Single Administrative Document) for each import. It is distinct from the VAT number and the OSS registration. For IOSS flows, the IOSS number must be communicated to the carrier so that VAT is not collected a second time at the border.

At Cabinet Hayot Expertise in Paris, we coordinate OSS registration and EORI filing from the outset of the international e-commerce engagement, to avoid VAT double-charging and customs delays.

The underestimated risk: reduced-rate products in a mixed catalogue#

The most common anomaly in e-commerce files handled by Cabinet Hayot Expertise in Paris: a seller systematically applying the standard rate across all EU sales, including to products qualifying for a reduced rate in certain Member States (books, food supplements, childcare articles). Over-collecting VAT creates a debt towards customers; under-declaring in reduced-rate countries creates a risk of tax adjustment. Correcting this requires reworking historical exports and recalculating the VAT differential by country.

Credit notes and returns: quarterly treatment#

A merchandise return generates a credit note that reduces the OSS VAT base. If the return occurs in the same quarter as the sale, it offsets directly in the return. If it falls in a later quarter, the credit note is reported on the OSS return for the quarter of the return. A credit note amount can make a country's base negative for the quarter — this is permitted and carried forward to the following return.

Distance thresholds by country: abolished since July 2021#

A persistent source of confusion: the old distance thresholds by country (€35,000 for France, €100,000 for Germany, etc.) were abolished on 1 July 2021. Only a single global threshold of €10,000 for all EU B2C sales now exists. This rule is stable; no change is expected in 2026.

ViDA reform: anticipating 2025–2028 changes#

The ViDA directive (VAT in the Digital Age), adopted by the EU Council in November 2024, introduces changes affecting marketplaces and the OSS scheme between 2025 and 2028. In 2025, extension of the deemed-supplier rule to short-term accommodation and passenger transport services (subject to national transposition into French law). In 2028, mandatory e-invoicing and real-time transaction data reporting (digital reporting requirements). These reforms are being transposed; their practical rules will be specified by the BOFiP as publications are released.

DAC7: platform reporting obligations since 2023#

EU Directive DAC7 (transposed in France as Article 1649 ter A of the CGI) has since 2023 required digital platforms to report their active sellers' revenues to tax authorities. Amazon, Shopify, and Stripe now transmit this data to the DGFiP automatically. In practice, the DGFiP holds a consolidated view of your platform revenues, which it can cross-reference with your OSS VAT returns and corporate tax filings. The consistency between your platform exports, OSS returns, and annual accounts must be flawless.

OSS rectification procedure#

If you discover an error on a previously filed OSS return — a missed country, incorrect rate, or omitted credit notes — the correction is made on the current quarter's return by adding or subtracting the affected amounts on the relevant country lines. An explanatory note in the filing is recommended to document the correction.

Foreign VAT refund and over-declared VAT#

If you have over-declared VAT for a Member State through OSS, the overpayment is not refunded by the DGFiP: it must be claimed from the tax authority of the relevant Member State via the foreign VAT refund procedure under Directive 2008/9/EC. This administrative process can take several months. It justifies addressing corrections promptly, within the quarter, rather than allowing gaps to accumulate.

Applicable penalties#

In the event of non-filing or late filing of an OSS return:

• Late interest: 0.20% per month (CGI art. 1727), equivalent to 2.4% per year, calculated on the VAT due
• 10% surcharge for a declaratory failure (CGI art. 1728)
• 40% surcharge for deliberate non-compliance, or 80% for fraudulent conduct (CGI art. 1729)
• Exclusion from the OSS scheme for repeated non-regularisation within the deadlines set by the tax authority

Article L102 B of the Tax Procedures Code requires retaining supporting documents for VAT transactions for 10 years. For e-commerce sellers under OSS/IOSS, this covers: platform transaction exports (Amazon, Shopify, Stripe), delivery or provision proof, rate mapping files, filed OSS returns, payment confirmations, and credit notes or refunds.

For B2C sales where no individual invoice is issued, the structured PSP export and the Seller Central report constitute an acceptable audit trail. Cabinet Hayot Expertise in Paris recommends a retention folder structure by year, by scheme (OSS / IOSS / standard VAT return) and by quarter, stored in a certified digital vault or compliant DMS, with direct access for the accounting and tax team.

The bookkeeping and accounting review service we provide includes a systematic check of OSS VAT archive completeness during the annual review, in preparation for any potential tax inspection.

Quarterly OSS filing is straightforward once the operational pipeline is in place. The real challenge is upstream: reliable platform exports, an up-to-date rate mapping for each product category in each country, and a reconciliation table that justifies every line of the declaration.

E-commerce files reviewed at Cabinet Hayot Expertise in Paris consistently reveal two weaknesses: one on rates (standard rate applied by default to goods qualifying for a reduced rate in certain countries), the other on the marketplace/direct storefront split (confusion as to who is liable depending on the sales channel). These two points are the first things we check when onboarding a new e-commerce client.

In 2026, with DAC7 at full speed and ViDA approaching in 2028, the consistency between platform data, VAT returns, and corporate tax filings has become a structural tax audit risk. A documented reconciliation pipeline is no longer good practice only: it is active protection against the automated data cross-referencing now routinely performed by the tax authority.

• Légifrance, CGI art. 298 sexdecies F (OSS Union scheme)
• Légifrance, CGI art. 298 sexdecies G III (IOSS scheme)
• Légifrance, CGI art. 256 V (deemed-supplier rule, since 1/7/2021)
• Légifrance, CGI art. 1727 (late interest) and art. 1729 (penalties)
• Légifrance, LPF art. L102 B (10-year archiving)
• BOFiP, BOI-TVA-DECLA-20-30-30 (OSS declaration)
• European Commission, One Stop Shop — OSS/IOSS guidance (ec.europa.eu)
• French Customs, EORI and SAD (douane.gouv.fr)