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FAQ: Fiscal Representation

Your 10 most frequently asked questions relating to fiscal representation and VAT.

From 1st January 2021, when the UK becomes a third country for VAT purposes after the end of the transition period, most UK businesses with EU VAT registrations will need to appoint a fiscal representative. In addition, some countries also require businesses to put a financial guarantee in place. This raises many questions for both business-to-business (B2B) and business-to-consumer (B2C) sales; even more for companies with complex supply chains.

Find your most frequently asked questions answered below and for a quick overview of key definitions around fiscal representation and VAT, read more here


In most EU countries, your VAT number will not change. However, EU tax authorities will continue to offer further guidance on this.


While we await further guidance from tax authorities on this, we recommend all VAT filings to be kept up to date where possible.

A transfer to fiscal representation will normally take a couple of weeks. However, we expect this to take longer as the Brexit deadline approaches. Local tax authorities will receive a large number of requests at the same time, so planning ahead of time is key.

No – it is a legal requirement to appoint a fiscal representative in the relevant EU Member State as a condition of retaining your VAT registration. This is only subject to country-specific easements or relaxations of the rules around fiscal representation. As a result, penalties and or VAT de-registration may apply if you do not comply.

Yes – for most Member States, we can prepare all the transfer forms to be ready to submit for when you would like to proceed. 

No – fiscal representation does not affect VAT rates.

No – fiscal representation does not in itself affect the filing frequency of your VAT return.

Transactions will be reported in the same way but the transactions you undertake may change. This depends on your business model and planned activity, so action is required to prepare and plan your supply chains and UK-EU transactions as well as potential reporting requirements. 

The appointment of a fiscal representative does currently not impact the requirement to file additional VAT declarations. However, once the transition period ends when the UK no longer receives treatment as an EU Member State, VAT treatment of transactions will likely change. This will impact the possible requirement for additional declarations which will be fully reviewed as we get closer to January 1st.

Some Member States require a fiscal representative for VAT recovery under 13th Directive claims, documentation required can vary significantly.

What now? 

The first step is to understand where you require fiscal representation within your supply chain. In collaboration with our close partners, our extensive network provides complete coverage across the EU. Our comprehensive service will guide you through the complexities of appointing fiscal representatives and understanding and meeting ongoing VAT obligations. 

Contact us now

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