When the marketplace owes the VAT, not you
Since July 2021 an online marketplace can be treated as if it bought your goods and resold them, purely for VAT. When that happens the platform charges and remits the VAT, and your sale to the customer disappears from your VAT return — replaced by a supply to the marketplace at zero. The rule is mechanical, it depends on facts you already know, and it catches sellers out because it applies to some of their orders and not others.
The two situations that trigger it
The marketplace becomes the deemed supplier in exactly two cases. Both require a sale to a consumer, not to a business.
1. Imported goods in a consignment up to 150 €. Goods sent to an EU consumer from outside the EU, regardless of where the seller is established. This is the case that pairs with IOSS — see import VAT under €150.
2. Goods already inside the EU, sold by a non-EU seller. Any value, no threshold. A Chinese or British seller with stock in a German warehouse selling to a French consumer through a platform: the platform owes the VAT.
Everything else stays yours. An EU-established seller shipping EU stock to an EU consumer is the ordinary case, and the platform is only a platform — it takes its commission and nothing about the VAT changes.
The table that answers it
| Seller established | Goods located | Buyer | Who owes the VAT |
|---|---|---|---|
| EU | EU | Consumer | You — OSS or a local registration |
| EU | Outside the EU, consignment ≤ 150 € | Consumer | Marketplace |
| EU | Outside the EU, consignment > 150 € | Consumer | You, or the buyer on import |
| Non-EU | EU | Consumer | Marketplace, any value |
| Non-EU | Outside the EU, consignment ≤ 150 € | Consumer | Marketplace |
| Anyone | Anywhere | Business (valid VAT number) | You — never the marketplace |
Read the last row twice. The deemed supplier rules cover B2C only. A B2B order through the same marketplace, on the same day, from the same warehouse, is entirely yours to account for — usually as a reverse charge supply if the customer is in another member state.
What it does to your own numbers
When the platform is the deemed supplier, the single sale is split into two for VAT purposes: you supply the marketplace, and the marketplace supplies the customer. Your leg is exempt or zero-rated with the right to deduct, which means you still reclaim your input VAT.
Three consequences that show up in practice:
Your turnover does not shrink, but your output VAT does. The money still arrives. What changes is that none of it is VAT you owe. Sellers who reconcile by looking at output VAT alone conclude they have a bookkeeping error when they do not.
The OSS threshold is not affected the way people assume. Deemed supplies are not your distance sales, so they do not count toward your 10 000 € — but your own non-deemed sales still do. If you sell both through a platform and from your own shop, only the second stream counts. The OSS threshold calculator is for that second stream.
You may still need the registration. Holding stock in another member state requires a local VAT number there whether or not the marketplace is the deemed supplier on the sales out of it. The rule moves the liability on the sale, not the obligation created by the stock.
Why your margin does not improve
The commonest misreading is that deemed supplier status is a saving. It is not. The customer pays the same gross price and the same VAT goes to the same treasury; only the party remitting it changes.
What does change is your cash flow, and usually for the better: you receive the net amount and never hold the VAT, so there is no quarterly outflow of money you were temporarily keeping. If your payout reports suddenly look smaller than last year for the same volume, this is normally why — the VAT is being deducted before payout rather than after.
Fee calculations are unaffected in principle but easy to get wrong in practice, because the commission base may be the gross figure while your revenue is the net one. Check which one your platform uses before comparing channels — the FBA calculator and the Allegro calculator both let you set the commission base explicitly for that reason.
What the platform will ask you for
The marketplace cannot apply the rule without knowing three things, and it will collect them from you whether or not you volunteer them: where you are established, where the goods ship from, and whether the buyer gave a valid VAT number.
Establishment is the one sellers get wrong. It is not where your company is registered on paper — it is where you have the human and technical resources to make supplies. A non-EU company with a warehouse but no staff in the EU is usually still non-EU established, which keeps it in the deemed supplier regime. Getting this wrong in your seller account produces VAT charged on the wrong side for months before anyone notices.
Keep the platform’s determination and your own records aligned. When they disagree, the tax authority will ask you, not the platform, why your return does not match the data it already has.
Where it stops
The rules cover goods. Services sold through a platform follow the ordinary place-of-supply rules, with a separate — and older — presumption for electronically supplied services, where the platform is treated as the supplier unless it does not authorise the charge or the delivery.
They also cover marketplaces, meaning a platform that facilitates the supply. A shop running on hosted software you rent is not a marketplace: nobody is facilitating your sale but you. Sellers on their own storefronts sometimes assume the rules protect them and file nothing.
And they stop at the warehouse door. Stock held in another member state needs a local VAT number whether or not the platform owes the tax on the sales that leave it. The rule moves the liability on the sale, not the obligation created by the stock — the distinction handled in OSS or local registration.
Frequently asked questions
You do. You are EU-established, the goods are in the EU, so no deemed supply arises — this is an ordinary distance sale, handled through OSS once you pass the 10 000 € threshold or opt in voluntarily.
They work together. For imported consignments up to 150 € sold through a marketplace, the marketplace is the deemed supplier and it is normally the marketplace’s IOSS number that is used. You would need your own IOSS registration for the same goods sold through your own shop.
No. They are not your distance sales for VAT purposes. Your other cross-border B2C sales still count, so a seller close to the threshold has to track the two streams separately rather than reading one total off a dashboard.
The status is determined at the time of supply on the information the platform held then. A number supplied afterwards does not retroactively convert a B2C sale into a B2B one; it is a correction to be handled between you and the customer, usually with a credit note and a new invoice.
For your leg to the marketplace, yes, and it is exempt with the right to deduct. The invoice to the consumer is the marketplace’s to issue. Issuing your own VAT invoice to that consumer as well would charge the tax twice.