Import VAT Deferment: How Not to Pre-Finance Tax You Get Back Anyway

Move stock into the EU rather than shipping parcel by parcel, and you avoid the €3 duty on customer orders. But you meet a different problem first, and it's a cash problem rather than a cost one.

On a €100,000 inbound shipment, import VAT at 21% is €21,000 leaving your account before you've sold a single unit. You get it back. You get it back weeks later, on your next VAT return, after you've already funded it.

There is a way to make that outflow not happen at all, and most of the EU offers it. The two best-known versions are Article 23 in the Netherlands and Article 33a in Poland. Which you can use, and what it costs to set up, should be part of deciding where your EU stock sits, not an afterthought once you've signed a warehouse contract.

In this article:

• Why postponed accounting and deferred payment are not the same thing, and why brands pick a country expecting the first
• What Article 23 (Netherlands) and Article 33a (Poland) actually require from a non-established business
• Where Germany sits, and why import VAT deferment has nothing to do with the €3 duty

First, a correction worth making

You'll read in a lot of places that the Netherlands is the only EU country with a favourable import VAT facility. It isn't, and it hasn't been for years.

The VAT Directive lets member states set their own rules for paying import VAT, and all of them apply either postponed accounting, deferred payment, or both. The Dutch scheme is the most marketed, not the only one.

The distinction between those two mechanisms matters more than the country names:

Postponed accounting means the import VAT is declared and deducted on the same periodic VAT return. Where your input tax is fully deductible, the net cash movement is zero. Nothing leaves your account, ever.

Deferred payment means you still pay, just later, typically against a guarantee. It smooths the timing. It doesn't remove the outflow.

Brands routinely choose a country on the assumption they're getting the first and end up with the second.

What it's worth in cash

Run it on your own numbers before you care about the legal detail.

Take a brand importing €80,000 of stock per quarter into an EU warehouse. Standard VAT rates on that import would be 19% in Germany, 20% in France, 21% in the Netherlands, Belgium and Spain, 23% in Poland.

At 21%, that's €16,800 per shipment. Four shipments a year is €67,200 of VAT cycling through your bank account, each tranche sitting with the tax authority for however long it takes between clearance and your return being filed and processed.

You never lose the money. What you lose is the use of it, and the working capital headroom it occupies at exactly the moment you're also funding inventory, freight and duty. For a brand growing quickly, that headroom is the constraint, not the tax.

Postponed accounting removes it entirely. That's the whole product.

The Netherlands: Article 23

The best-known scheme, and the reason a lot of non-EU brands route European imports through Rotterdam.

What it does. Shifts import VAT from the moment of clearance to your periodic Dutch VAT return, where it's declared and deducted in the same filing. Usually nets to zero cash out.

Who can hold it. Dutch legal entities and fixed establishments apply directly. A business not established in the Netherlands cannot shift the VAT to a return on its own: it must appoint a fiscal representative. That representative provision sits at Article 33a of the Dutch VAT Act, which is a completely different thing from the Polish Article 33a below. The overlap in numbering causes real confusion, so be precise about which country you mean.

What it requires. A Dutch VAT number first. Records that clearly identify the VAT owed on each import, which in practice means a distinct ledger or module in your accounting system so officials can verify import values. And a mandatory financial guarantee, with a minimum around €5,000 that scales with your import volume and risk profile. For non-residents, the guarantee is often provided by the fiscal representative as part of their mandate.

The trade-off. A mature market of fiscal representatives who do this at volume, against a dependency on that representative and the cost and liability chain it creates.

Poland: Article 33a

Poland's equivalent works differently. It isn't a licence with a capital requirement.

What it does. Under Article 33a of the Polish VAT Act, a registered active VAT taxpayer accounts for import VAT in the return for the period in which the tax obligation arose, showing it as output tax and, where deductible, as input tax in the same filing.

Who can use it. This is where older guidance is actively wrong. Until mid-2021 the mechanism was restricted to businesses holding AEO status or an authorisation for simplified customs procedures. That restriction was removed on 1 July 2021. It's now open to any taxpayer meeting the conditions, which is a materially different proposition for a mid-sized brand.

What it requires. Registration as an active VAT taxpayer in Poland. Certificates or declarations showing no material arrears in taxes or social security contributions, issued no earlier than six months before the import. Notification to the head of the relevant customs and tax office. Reporting through the standard JPK_V7 filing.

The trap. Elect to use Article 33a and then fail to account for the tax in the correct period, and you lose the right for that amount and become liable for the VAT plus interest. There's a correction window, but treat the deadline as real. Your customs representative can carry joint liability with you for correct settlement, which is why agencies are selective about who they file for.

Germany: the cautionary case

Worth its own section, because Germany is where a lot of UK brands instinctively want their EU stock, and where the VAT position is weakest.

Germany does not currently offer postponed accounting. It offers deferred payment: roughly a 28-day delay on import VAT that would otherwise be due at clearance, and in many cases requiring a bank guarantee. Deferrals come in several forms, with ongoing deferral typically requiring a minimum shipment frequency, and generally only EU-established businesses can apply directly, with non-EU businesses accessing it through a customs representative.

Reform has been promised in the governing coalition agreement, on the reasoning that German ports and land customs points are losing import business to member states with more favourable regimes. Until it lands, a brand choosing Germany for its logistics is choosing to pre-finance VAT that a brand choosing the Netherlands or Poland isn't.

That is not on its own a reason to avoid Germany. It is a reason to price it.

Elsewhere, briefly

Belgium allows postponement to the VAT return under an E.T. 14.000 licence, which is not subject to a guarantee, and UK businesses filing periodic Belgian VAT returns can use it.

France introduced import VAT deferment more recently, with non-EU businesses able to apply for postponed accounting where they have a fiscal representative holding Authorised Economic Operator status, via a specific authorisation valid up to three years.

Spain has operated postponed accounting since 2015.

Slovakia introduced postponed accounting for resident VAT payers in July 2025 and extended it to foreign VAT-registered payers from January 2026, subject to application and authorisation.

The pattern is that this is normalising across the EU. The question isn't whether a country has something, it's whether what it has removes the cash outflow or merely delays it, and what hoop you have to clear as a non-established business.

How this connects to the €3 duty, and how it doesn't

Two things worth stating plainly, because they get conflated constantly.

Deferment is not exemption. You still owe the VAT. You're changing when and how it's settled. If your input tax isn't fully deductible, the netting doesn't fully net.

Deferment has nothing to do with the €3 duty. These are separate charges under separate rules. Import VAT is a consumption tax; the €3 is a customs duty on low-value consignments arriving from outside the EU. Deferring one doesn't touch the other.

What removes the €3 from your customer orders is holding stock inside the EU so those orders ship domestically. Import VAT deferment is what makes that move affordable in month one rather than month six. They're two halves of the same decision, which is why doing them in the wrong order costs money.

The order that avoids rework

Decide which country your stock should sit in, based on fulfilment cost, transit time to your biggest markets, and returns

Establish what import VAT treatment that country actually offers, postponed accounting or merely deferred payment, and what a non-established business has to do to access it

Register: VAT in the country of storage, One Stop Shop for your EU distance sales, EORI

Apply for the deferment mechanism, allowing lead time for guarantees or certificates

Then book the first inbound shipment

Doing it the other way round, picking a country for its VAT scheme and discovering the fulfilment economics don't work, is more expensive than pre-financing VAT for a quarter.

This is a compliance decision with genuine liability attached. Take local advice on your specific structure rather than acting on a guide, this one included.

FAQ

What's the difference between postponed accounting and deferred payment? Postponed accounting means import VAT is declared and deducted on the same VAT return, so with full deductibility no cash moves at all. Deferred payment means you still pay, just later, usually against a guarantee. Both help; only the first removes the outflow. Check which one a country is actually offering before you choose it.

Which EU countries offer this? All member states apply either postponed accounting, deferred payment, or both, under the VAT Directive's provisions on payment of import VAT. What varies enormously is the mechanism, the conditions, and what a non-established business has to do to qualify.

Can a UK company use the Dutch Article 23 licence? Not directly. A business without an establishment in the Netherlands can't shift import VAT to a Dutch return on its own and must appoint a fiscal representative, who typically also provides the required financial guarantee as part of their mandate.

Is Poland's Article 33a still restricted to AEO holders? No, and this is the most common outdated claim in circulation. The AEO or simplified-procedure requirement was removed on 1 July 2021. It's now available to any active VAT taxpayer meeting the conditions, which include current certificates on tax and social security arrears issued within the previous six months.

Why is Germany treated separately here? Because Germany currently offers deferred payment, not postponed accounting: broadly a 28-day delay, often against a bank guarantee, with non-EU businesses generally needing a customs representative to access it. Reform is promised in the coalition agreement but isn't in place. If you're choosing Germany for logistics reasons, budget for pre-financing the VAT.

Does deferment reduce what I owe? No. It changes the timing and the mechanism, not the amount. The benefit is working capital, not tax saving.

Does any of this affect the €3 duty? No. Separate charge, separate rules. Import VAT deferment helps you fund the bulk import; holding stock in the EU is what stops the €3 applying to your customer orders.

How long does it take to set up? Long enough that it belongs at the start of an EU move rather than the end. VAT registration, then guarantees or certificates, then authorisation. Build it into the timeline before you book inbound freight.

Not sure what your current setup is costing you?

Send us your numbers and we'll run them against the new regime: where the duty hits twice, what return freight costs against the goods you recover, and how much is avoidable.