VAT Concepts Explained: E-Commerce & Platforms: Deemed Supplier Rules, OSS/IOSS, Marketplace Liability, and Returns

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E-Commerce & Platforms: Deemed Supplier Rules, OSS/IOSS, Marketplace Liability, and Returns

A Global VAT/GST Analysis for Multinational Business Leaders and Tax Practitioners

Published: June 06, 2026

Disclaimer: This article is for informational purposes only and does not constitute legal, tax, or professional advice. Readers should consult qualified advisers before acting on any information contained herein. No confidential or company-specific information is included.

A. Executive Summary

The rapid expansion of cross-border e-commerce has fundamentally reshaped how governments collect VAT and GST. Since July 2021, the EU has required online marketplaces (“electronic interfaces”) to act as deemed suppliers for certain B2C transactions—collecting, reporting, and remitting VAT on behalf of underlying sellers. This is complemented by the One Stop Shop (OSS) and Import One Stop Shop (IOSS), which allow businesses to consolidate VAT reporting across all 27 Member States through a single portal. Similar models have been adopted by the UK, Norway (VOEC), Switzerland (from January 2025), Australia, Singapore, and others, broadly following OECD guidance on the role of digital platforms in VAT/GST collection.

These rules create a two-stage deemed supply chain—splitting what is commercially one transaction into a B2B supply (seller to platform) and a B2C supply (platform to consumer)—with significant implications for VAT registrations, invoicing, input VAT recovery, ERP configuration, and audit exposure. The ECJ has confirmed the validity of these deemed supplier mechanisms in landmark rulings including Fenix International (C-695/20) and Xyrality (C-101/24). With ViDA extending deemed supplier obligations to short-term accommodation and passenger transport platforms from July 2028, and the EU customs duty de minimis removal taking effect from July 2026, businesses must act now to prepare governance frameworks, system controls, and contractual arrangements.

B. Concept Definition and Legal Framework

B.1 Definition

The “deemed supplier” concept is a legal fiction under which a digital platform or marketplace is treated, for VAT purposes, as having received goods or services from the underlying seller and having supplied them onward to the end customer. The platform assumes VAT collection and remittance obligations, even though it never takes legal ownership of the goods. In the EU, this is codified in Article 14a of the VAT Directive 2006/112/EC (for goods) and Article 28 read with Article 9a of Implementing Regulation 282/2011 (for electronically supplied services).

B.2 Why the Concept Exists (Policy Logic)

Tax authorities worldwide identified that the explosive growth of e-commerce created a structural VAT gap: millions of small non-EU sellers were making taxable supplies to EU consumers without registering for or remitting VAT. Traditional enforcement against individual sellers proved impractical. The policy response was to shift the VAT collection obligation to the marketplace—a single, identifiable point of control in the supply chain. The European Commission estimated that the 2021 e-commerce package would reduce the administrative burden for businesses by up to 95% while closing billions in VAT leakage. In 2023, IOSS declarations alone reached over €26.3 billion, a 35% year-on-year increase (European Commission, May 2025).

B.3 Key Tests and Decision Tree

To determine whether deemed supplier rules apply, businesses must assess three sequential questions:

1. Step 1 – Is there an “electronic interface”? The EU defines this as a marketplace, platform, portal, or similar means that enables third parties to offer goods for sale (Article 14a; Council Implementing Regulation 2019/2026). This includes websites, mobile apps, and app stores.
2. Step 2 – Does the platform “facilitate” the supply? Facilitation exists where the platform controls terms and conditions, authorises the charge to the customer, or is involved in ordering/delivery. Merely providing payment processing, listing/advertising, or redirecting customers does not constitute facilitation (Article 5b, Implementing Regulation 282/2011).
3. Step 3 – Is the transaction in scope? Two categories trigger deemed supplier status: (a) distance sales of imported goods in consignments ≤€150, regardless of seller establishment; and (b) any B2C supply of goods within the EU where the underlying seller is not established in the EU, regardless of value (Article 14a(1) and (2), VAT Directive).

If all three conditions are met, the platform is the deemed supplier and must collect VAT from the consumer, while the underlying seller makes a deemed exempt/zero-rated B2B supply to the platform.

C. Global Landscape (VAT/GST Perspective)

C.1 EU Approach

The EU’s e-commerce VAT package, effective 1 July 2021, introduced the most comprehensive deemed supplier framework globally. It comprises three pillars: (i) extension of the Mini One Stop Shop (MOSS) into the full OSS, covering intra-EU distance sales of goods and all B2C services; (ii) the IOSS for imported goods ≤€150; and (iii) the deemed supplier mechanism for electronic interfaces (Article 14a). The EU-wide distance selling threshold was unified at €10,000, replacing 27 separate national thresholds (Council Directive (EU) 2017/2455). The ViDA package, adopted on 11 March 2025 and published in the Official Journal on 25 March 2025, extends deemed supplier rules to platforms facilitating short-term accommodation rental and passenger transport by road, with voluntary application from 1 July 2028 and mandatory application from 1 January 2030 (Directive (EU) 2025/516).

C.2 Non-EU VAT/GST Countries

United Kingdom: The UK implemented its own deemed supplier rules from 1 January 2021 (post-Brexit). Online marketplaces are deemed suppliers for: (a) goods located in the UK sold by overseas sellers to UK consumers, and (b) goods imported in consignments ≤£135 by overseas sellers. Unlike the EU, the UK regime applies regardless of the seller’s establishment when goods are already in the UK and sold by a non-UK seller. Amazon has proposed extending the regime to all UK marketplace sales, estimating £3.2bn in annual VAT leakage from establishment-status fraud (HMRC guidance, updated June 2025).

Norway (VOEC): Norway’s VAT on E-Commerce (VOEC) scheme mirrors the EU’s IOSS framework. Foreign sellers of low-value goods (<NOK 3,000) and remotely deliverable services must register once turnover exceeds NOK 50,000. From 1 January 2024, all imports require VAT payment—the low-value exemption was abolished. Marketplace operators are treated as suppliers under the same criteria (Norwegian Tax Administration, Skatteetaten).

Switzerland: From 1 January 2025, Switzerland introduced EU-style deemed supplier rules under Article 20a VATA. Platforms facilitating goods sales become deemed suppliers for both cross-border and domestic supplies. The registration threshold is CHF 100,000 from low-value consignments. Sellers retain subsidiary liability alongside the platform. The Swiss Federal Tax Administration (ESTV) maintains a public register of platform operators (ESTV, May 2026).

Australia: Since 1 July 2017 (digital services) and 1 July 2018 (low-value goods ≤AUD 1,000), Electronic Distribution Platform (EDP) operators are deemed suppliers for GST purposes. The ATO treats EDPs as the entity making the supply when they are registered for GST and facilitate sales of imported low-value goods or digital services by overseas merchants to Australian consumers (ATO, LCR 2018/2).

Singapore: Under the Overseas Vendor Registration (OVR) regime (expanded January 2023), overseas suppliers and electronic marketplace operators must register for GST (9%) when global turnover exceeds SGD 1 million and B2C supplies to Singapore exceed SGD 100,000. Marketplace operators are deemed suppliers when they authorise the charge or delivery of supply (IRAS, e-Tax Guide, 3rd Edition, January 2026).

D. ECJ/CJEU Case Law Section

The following ECJ cases have shaped the interpretation of deemed supplier and platform liability rules in the EU:

D.1 Fenix International Ltd (C-695/20) – Grand Chamber – 28 February 2023

Facts: Fenix International, a UK company, operated the OnlyFans platform. Content creators uploaded content; subscribers paid fees. Fenix retained 20% as its service fee and forwarded 80% to creators. Fenix accounted for VAT only on its 20% commission, not on the full subscriber payments.

Legal issue: Whether Article 9a of Implementing Regulation 282/2011—which presumes that a platform facilitating electronically supplied services acts in its own name—is valid under EU law, or whether it exceeds the Council’s implementing powers under Article 397 of the VAT Directive.

Holding: The ECJ (Grand Chamber) upheld the validity of Article 9a. The provision merely clarifies Article 28 of the VAT Directive without supplementing or amending it. A platform that authorises the charge, controls payment, or sets general terms and conditions is irrebuttably deemed the supplier. The platform must account for VAT on the full amount received from end users.

Practical takeaway: Any platform controlling payment flows or setting terms for electronically supplied services bears VAT on total revenue, not just its commission. This applies retroactively to periods before 2015. Platforms must review contractual structures and ensure VAT is accounted for on gross customer payments.

D.2 Xyrality GmbH (C-101/24) – 9 October 2025

Facts: Xyrality, a German mobile game developer, distributed apps through an Irish-based app store. Apps were free to download, but users made in-app purchases. Order confirmations named Xyrality as the seller and showed German VAT, despite the app store controlling the entire transaction interface and payment process.

Legal issue: Whether the app store is the deemed supplier under Article 28/9a despite order confirmations naming the developer; how the place of supply is determined; and whether the developer is liable under Article 203 for VAT shown on confirmations.

Holding: The ECJ confirmed that the app store is the deemed supplier. Post-transaction order confirmations naming the developer do not override the economic reality that the app store controls the customer interface, payment, and terms. The place of supply for the developer’s deemed B2B supply to the app store is determined under Article 44 (B2B rule—Ireland). The developer is not liable under Article 203 for VAT shown on order confirmations sent to non-taxable persons.

Practical takeaway: Substance over form: the customer-facing role of the platform determines deemed supplier status, not post-sale documentation. Developers and service providers should align invoicing with the economic reality. Incorrect VAT shown on customer-facing documents does not create liability for the underlying supplier where recipients are non-taxable persons.

E. Selected Country Practices (8 Jurisdictions)

Country	Authority Approach	Typical Triggers	Evidence Expected	Risk
Germany (DE)	BZSt enforces deemed supplier; platforms must verify seller establishment via certificates (§ 22f UStG). Joint liability for platforms failing due diligence.	Non-EU seller on platform; missing seller certificates; consignments >€150 without standard import VAT.	Seller establishment certificates (§ 22f); transaction logs; IOSS/OSS return reconciliation.	HIGH
France (FR)	DGFiP requires platforms to report seller data (DAC7). Deemed supplier rules follow EU standard. Active enforcement on marketplace-facilitated imports.	Non-EU seller domestic sales; low-value imports via marketplace; missing IOSS numbers on customs declarations.	Platform seller reports; customs data cross-checks; IOSS registration evidence.	HIGH
Netherlands (NL)	Dutch Tax Administration actively audits marketplace compliance. Strong focus on correct OSS/IOSS usage and seller verification.	Incorrect VAT rate application via OSS; misclassification of facilitation; non-EU seller verification gaps.	OSS/IOSS returns; seller establishment documentation; platform terms analysis.	MED-HIGH
Belgium (BE)	SPF Finances follows EU standard implementation. Focus on cross-border distance sales and platform record-keeping (10-year retention).	Distance sales exceeding €10,000 threshold without OSS; platform record-keeping failures.	OSS registration; transaction records; proof of dispatch/transport.	MEDIUM
UK	HMRC applies deemed supplier rules since Jan 2021. Marketplace joint/several liability for non-compliant overseas sellers. Increasing data sharing with platforms.	Overseas seller using UK fulfilment; goods ≤£135 from outside UK; false UK establishment claims.	Seller establishment verification; fulfilment house records; platform transaction data.	HIGH
Norway	Skatteetaten operates VOEC scheme. Mandatory digital VOEC number from 2024. All imports now subject to VAT.	Sales to Norwegian consumers exceeding NOK 50,000; missing VOEC numbers on customs declarations.	VOEC registration; quarterly return filings; digital customs declarations.	MEDIUM
Switzerland	ESTV introduced deemed supplier (Art. 20a VATA) from Jan 2025. Public register of platform operators. Subsidiary seller liability.	Platform turnover from low-value consignments >CHF 100,000; failure to register; incorrect import VAT treatment.	ESTV platform register; seller disclosure; transaction-level VAT reporting.	MED-HIGH
Australia	ATO enforces EDP operator rules. GST on low-value goods (≤AUD 1,000) and digital services. Detailed guidance in LCR 2018/2.	Overseas merchant sales via EDP; failure to distinguish B2B from B2C; incorrect GST-free treatment of exports.	EDP operator registration; BAS filings; transaction records per LCR 2018/2.	MEDIUM

F. Why This Matters for Businesses

F.1 Operational Implications

Registrations: Platforms acting as deemed suppliers may need VAT registrations in multiple jurisdictions, unless OSS/IOSS is used. Non-EU sellers are relieved of individual registration obligations for in-scope transactions, but may still need local registrations for out-of-scope sales (e.g., B2B, goods >€150). The ViDA Single VAT Registration pillar (from July 2028) will further expand OSS to cover additional transaction types, including domestic supplies by non-established taxable persons.

Invoicing and Reporting: The deemed supply chain creates two taxable events from one commercial transaction. The underlying seller issues a B2B invoice to the platform (typically exempt/zero-rated); the platform issues the B2C supply documentation to the consumer. Under OSS, the platform files quarterly returns in its Member State of identification. Under IOSS, monthly returns are required. ERP systems must be configured to split transactions, apply correct destination-country VAT rates, and generate compliant documentation.

Cash Flow and Returns: Platforms bear the VAT remittance risk. Where goods are returned by consumers, the platform must adjust VAT in the period of the return. For IOSS transactions, if goods are returned after import, the import VAT exemption must be reversed, creating complex customs and VAT interactions. From July 2026, the removal of the €150 customs duty de minimis will add further complexity, as customs duties may apply even where IOSS handles VAT.

F.2 Supply Chain and Incoterms Implications

The deemed supplier fiction does not change the physical flow of goods or the commercial contract. However, it redefines who is responsible for VAT in the eyes of tax authorities. Incoterms (e.g., DDP vs. DAP) must be aligned with VAT obligations: a seller using IOSS effectively assumes DDP-like VAT responsibility at checkout, while customs duties remain separate. Misalignment between Incoterms and VAT treatment is a frequent audit trigger (practice-based observation).

F.3 E-Invoicing and E-Reporting Considerations

The ViDA Digital Reporting Requirements (DRR) pillar will require real-time digital reporting for cross-border B2B transactions from 1 July 2030, based on structured e-invoicing (EN 16931 standard). While deemed supplier B2C transactions are primarily reported via OSS/IOSS rather than DRR, platforms must ensure their invoicing systems can generate compliant structured data. Member States with existing domestic DRR systems (e.g., Italy’s SdI, Spain’s SII/VeriFactu, France’s PPF) must align with the EU model by 1 January 2035. Peppol-based e-invoicing is increasingly relevant for B2B legs of deemed supply chains.

G. Main Challenges, Controversies, and Risks

G.1 Legal Interpretation Challenges

The boundary between “facilitation” and mere intermediation remains contested. Platforms providing only listing/advertising services argue they should not be deemed suppliers, but tax authorities may take a broader view of “involvement” in the supply. The interaction between Article 14a (goods) and Article 28/9a (services) creates complexity for platforms offering mixed supplies. The upcoming ViDA extension to accommodation and transport platforms raises questions about the interplay with the Tour Operators Margin Scheme (TOMS) and Article 28 existing rules, as highlighted at the November 2025 Fiscalis Workshop in Madrid.

G.2 Process and System Challenges

Correct VAT rate determination across 27+ jurisdictions requires real-time tax engines integrated with checkout systems. Seller establishment verification is operationally difficult—the UK experience shows that false establishment claims are widespread. Returns processing under IOSS requires coordination between customs authorities, logistics providers, and VAT reporting systems. ERP systems (SAP, Oracle) require specific configuration for the two-stage deemed supply chain, and many legacy systems were not designed for this logic.

G.3 Audit and Dispute Trends

Tax authorities are increasingly cross-referencing platform transaction data (DAC7/OECD MRDP reports) with VAT returns to identify discrepancies. Common audit focus points include: incorrect classification of facilitation status; misapplication of the €150 IOSS threshold; failure to account for returns/refunds in the correct period; and incorrect seller establishment verification. Germany’s § 22f UStG joint liability provisions have been actively enforced, with platforms facing assessments for sellers’ unpaid VAT (practice-based observation).

H. How to Anticipate and Manage (Taxpayer Playbook)

H.1 Governance and Controls

Establish a cross-functional e-commerce VAT governance committee (Tax, IT, Supply Chain, Legal) with clear accountability. Define RACI matrices for deemed supplier determinations, OSS/IOSS registrations, and platform contract reviews. Implement quarterly reviews of deemed supplier applicability as business models evolve.

H.2 Contracting and Operating Model Alignment

Review all platform/marketplace agreements to identify facilitation triggers. Ensure contracts clearly allocate VAT responsibilities between the platform and the seller. For ViDA readiness, assess whether accommodation and transport platform contracts will need amendment by July 2028. Align Incoterms with the VAT treatment actually applied at checkout.

H.3 Documentation Package

Maintain a documented position on deemed supplier status for each platform relationship. Keep seller establishment certificates (where required, e.g., Germany’s § 22f) and evidence of facilitation analysis. Archive transaction-level data for at least 10 years (as required by several Member States). Document the rationale for OSS vs. local registration decisions.

H.4 Monitoring and Periodic Reassessment

Track KPIs including: number of deemed supplier transactions by jurisdiction; OSS/IOSS return accuracy rates; returns/refund adjustment timeliness; seller establishment verification completion rates; and VAT rate change implementation speed. Monitor legislative developments (ViDA implementation, IOSS reform, customs reform) through structured horizon-scanning.

I. Common Misconceptions

1. Misconception: “The platform always pays the VAT.”

Reality: Deemed supplier rules only apply to specific in-scope transactions. EU-established sellers making B2C sales via platforms are generally not covered by Article 14a—the seller remains the supplier and liable for VAT.

2. Misconception: “IOSS replaces all import VAT obligations.”

Reality: IOSS only covers consignments ≤€150. Goods above this threshold require standard import procedures. Moreover, from July 2026, customs duties will apply to low-value goods even when IOSS handles VAT.

3. Misconception: “OSS eliminates all local VAT registrations.”

Reality: OSS covers distance sales and certain services, but does not replace local registrations required for domestic stock holdings (e.g., Amazon FBA warehouses), B2B transactions, or supplies not in scope of OSS.

4. Misconception: “If the platform collects VAT, the seller has no obligations.”

Reality: Sellers must still maintain records, file local VAT returns for out-of-scope transactions, and in some jurisdictions (e.g., Switzerland) retain subsidiary liability for the platform’s deemed supplies.

5. Misconception: “Deemed supplier rules apply only to goods.”

Reality: Article 28/9a already applies to electronically supplied services. ViDA will extend deemed supplier rules to short-term accommodation and passenger transport services from 2028/2030.

6. Misconception: “Returns are straightforward under IOSS.”

Reality: Returns of imported goods create complex interactions between VAT and customs. The import VAT exemption may need reversal, and the consumer may need to claim a refund from the platform, not from customs.

7. Misconception: “A €10,000 threshold applies per country.”

Reality: The €10,000 threshold is EU-wide and cumulative across all Member States. It covers both distance sales of goods and TBE services. Once exceeded, destination-country VAT applies to all cross-border B2C sales.

8. Misconception: “Non-EU platforms are exempt from EU VAT rules.”

Reality: Non-EU platforms facilitating in-scope sales to EU consumers must comply with deemed supplier obligations, register for OSS/IOSS (appointing an intermediary if required), and collect EU VAT.

J. Practical Checklist

• Map all marketplace/platform relationships and classify each as “facilitating” or “non-facilitating” under EU/local rules.
• Determine deemed supplier status for each platform-transaction combination (goods vs. services; seller establishment; consignment value).
• Register for OSS and/or IOSS where applicable; appoint intermediaries for non-EU entities.
• Configure ERP/tax engine to split deemed supply chains into B2B (seller→platform) and B2C (platform→consumer) legs.
• Implement real-time VAT rate determination for all 27 EU Member States (plus UK, Norway, Switzerland as applicable).
• Establish seller establishment verification procedures, including certificates under § 22f UStG (Germany) or equivalent.
• Develop returns/refund processing workflows that correctly adjust VAT in the reporting period of the return.
• Ensure IOSS numbers are correctly communicated to logistics providers and included on customs declarations.
• Prepare for the removal of the €150 customs duty de minimis from 1 July 2026—model duty exposure and update pricing.
• Review and update platform contracts to clearly allocate VAT collection, reporting, and liability responsibilities.
• Implement DAC7/OECD MRDP reporting capabilities for seller transaction data.
• Archive transaction records for the period required by each jurisdiction (typically 7–10 years).
• Train finance, tax, and supply chain teams on deemed supplier rules and OSS/IOSS procedures.
• Establish monitoring KPIs: OSS/IOSS filing accuracy, returns adjustment timeliness, seller verification completion.
• Conduct annual deemed supplier status reassessment as business models and legislation evolve.
• Assess ViDA readiness: accommodation/transport platform deemed supplier rules (voluntary from July 2028, mandatory from January 2030).
• Coordinate with customs brokers on the interaction between IOSS VAT treatment and customs duty obligations.
• Document all positions, analyses, and decisions in a centralized tax governance repository.

K. Top 10 Takeaways

• Deemed supplier rules shift VAT collection responsibility from millions of individual sellers to a manageable number of platforms—this is the single most significant structural change in VAT enforcement in decades.
• The ECJ has firmly upheld the validity and broad application of deemed supplier rules (Fenix C-695/20; Xyrality C-101/24), eliminating legal uncertainty about the mechanism’s foundations.
• OSS and IOSS dramatically simplify compliance but do not eliminate the need for local VAT registrations where goods are stored or where transactions fall outside their scope.
• The global convergence toward platform VAT liability (EU, UK, Norway, Switzerland, Australia, Singapore, Japan) means multinationals must manage compliance across multiple regimes simultaneously.
• ViDA will extend deemed supplier obligations to accommodation and transport platforms from July 2028—early preparation is essential.
• The removal of the €150 customs duty de minimis from July 2026 will increase costs and complexity for IOSS users, even though the VAT framework remains unchanged.
• Returns processing under deemed supplier regimes is operationally complex and a frequent source of errors—dedicated workflows are required.
• Seller establishment verification is both a legal requirement and a practical challenge—platforms face joint liability for sellers’ unpaid VAT in several jurisdictions.
• ERP and tax engine configuration for the two-stage deemed supply chain is non-trivial and requires dedicated project investment.
• Cross-referencing of platform data (DAC7/MRDP) with VAT returns by tax authorities is increasing—discrepancies will trigger audits.

L. Board-Level Summary (5 Bullets)

• VAT collection on e-commerce has been structurally shifted to platforms: if our business operates or sells through marketplaces, we are directly affected by deemed supplier obligations in the EU, UK, and at least 10 other major jurisdictions.
• The financial exposure is material: platforms that fail to comply face VAT assessments on full transaction values (not just commissions), plus penalties and joint liability for sellers’ unpaid VAT.
• Regulatory momentum is accelerating: ViDA (adopted March 2025) will extend platform obligations to accommodation and transport by 2028/2030; customs reforms from July 2026 add cost complexity.
• System and process readiness is critical: ERP configuration, real-time tax engines, seller verification, and returns handling all require investment before compliance deadlines.
• Governance must be cross-functional: Tax, IT, Supply Chain, Legal, and Commercial teams must collaborate through a structured framework with clear accountability and regular reassessment.

M. Tax Team Action Plan (10 Bullets)

• Conduct a comprehensive inventory of all marketplace/platform relationships across the group and classify deemed supplier applicability.
• Validate current OSS/IOSS registrations and assess whether additional registrations or intermediary appointments are needed.
• Commission ERP/tax engine review to ensure correct two-stage deemed supply chain configuration and destination-country VAT rate application.
• Implement or strengthen seller establishment verification processes, particularly for German § 22f requirements.
• Develop dedicated returns/refund VAT adjustment procedures with clear handoffs between logistics, finance, and tax teams.
• Prepare a ViDA impact assessment covering accommodation and transport platform relationships, with a timeline for contract amendments by H1 2028.
• Model the financial impact of the July 2026 customs duty de minimis removal on IOSS-eligible transactions.
• Establish a DAC7/MRDP compliance workstream to ensure seller reporting obligations are met and data is consistent with VAT returns.
• Schedule quarterly deemed supplier status reviews and annual training for all stakeholders.
• Create a regulatory monitoring dashboard tracking ViDA transposition, IOSS reform, customs reform, and relevant ECJ case developments across priority jurisdictions.

N. Sources & Further Reading

EU Law

• Council Directive 2006/112/EC (VAT Directive), Articles 14a, 28, 44, 203 – https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32006L0112
• Council Implementing Regulation (EU) No 282/2011, Article 9a – https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011R0282
• Council Directive (EU) 2017/2455 (e-commerce VAT package) – https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32017L2455
• Council Directive (EU) 2025/516 (ViDA) – https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202500516
• European Commission, VAT e-Commerce One Stop Shop portal – https://vat-one-stop-shop.ec.europa.eu/index_en
• European Commission, ViDA overview – https://taxation-customs.ec.europa.eu/taxation/vat/vat-digital-age-vida_en
• European Commission, Explanatory Notes on VAT e-commerce rules (2020) – https://taxation-customs.ec.europa.eu/taxation/vat/vat-e-commerce_en

ECJ Cases

• ECJ C-695/20, Fenix International Ltd (OnlyFans), 28 February 2023 – https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:62020CJ0695
• ECJ C-101/24, Finanzamt Hamburg-Altona v Xyrality GmbH, 9 October 2025 – https://curia.europa.eu

National Guidance

• HMRC (UK), Charging VAT when using an online marketplace, updated June 2025 – https://www.gov.uk/guidance/charging-vat-when-using-an-online-marketplace-to-sell-goods-to-customers-in-the-uk
• Skatteetaten (Norway), VOEC scheme – https://www.skatteetaten.no/en/business-and-organisation/vat-and-duties/vat/foreign/e-commerce-voec/
• ESTV (Switzerland), VAT registration for platform operators – https://www.estv.admin.ch/en/vat-registration-for-platform-operators
• ATO (Australia), EDP operator guidance – https://www.ato.gov.au/businesses-and-organisations/international-tax-for-business/gst-for-non-resident-businesses/how-to-charge-gst/if-you-are-an-edp-operator
• IRAS (Singapore), GST Guide for e-Commerce, 3rd Edition, January 2026 – https://www.iras.gov.sg/media/docs/default-source/e-tax/gst-guide-for-e-commerce.pdf
• BZSt (Germany), § 22f UStG platform liability – https://www.bzst.de

OECD and Other

• OECD, Model Reporting Rules for Digital Platforms (MRDP) – https://www.oecd.org/en/topics/sub-issues/international-tax-compliance-policies-and-best-practices/model-reporting-rules-for-digital-platforms.html
• OECD, FAQs on Model Reporting Rules, updated October 2023 – https://www.oecd.org
• EU DAC7 (Council Directive (EU) 2021/514) – https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32021L0514

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