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EU: In which countries do UK entities have to appoint a fiscal representative after the Brexit?

Over the last couple of days, Belgium has approached UK entities having a Belgian VAT registration number to appoint a fiscal representative. This would indeed be needed in case the UK leaves the European Union and UK entities become non-EU established entities (scheduled still for 31 December 2020).

However, many other EU countries require non-EU entities to appoint a fiscal representative.

Country Fiscal rep for non-EU companies Fiscal rep for EU companies
Austria Required Optional
Belgium Required Not required
Bulgaria Required (unless there is a legal instruments for mutual assistance) Optional
Croatia Required Optional
Cyprus Required (unless bank guarantee is deposited with the tax authorities) Optional
Czech Republic Not possible Not possible
Denmark Required – Optional for Norway, Greenland, Iceland and the Faroe Islands Optional
Estonia Optional Optional
Finland Required (Optional in case treaty has been concluded concerning mutual assistance by the competent authorities as regards indirect taxes) Optional
France Required (Optional in case treaty has been concluded concerning mutual assistance by the competent authorities as regards indirect taxes) – France has indicated unofficially that UK business would need to have a fiscal representative in the UK – to be confirmed Optional
Germany Optional Optional
Greece Optional Optional
Hungary Required Optional
Ireland Not required – not possible Not required – not possible
Italy Required (Optional in case treaty has been concluded concerning mutual assistance by the competent authorities as regards indirect taxes) Optional
Latvia Optional Optional
Lithuania Required Optional
Luxembourg Optional Optional
Malta Optional Optional
Netherlands Required Optional
Poland Required Optional
Portugal Required Optional
Romania Required Optional
Slovakia Not required (possible in limited cases) Not required (possible in limited cases)
Slovenia Required Optional
Spain Required Optional
Sweden Required (Optional in case treaty has been concluded concerning mutual assistance by the competent authorities as regards indirect taxes) Optional
United Kingdom (until Brexit) Required (Optional in case treaty has been concluded concerning mutual assistance by the competent authorities as regards indirect taxes) Optional