One threshold for the whole EU, not one per country
This is the part that catches people. Before 2021 each member state had its own distance selling threshold, often €35,000 or €100,000, and you tracked them separately. That system is gone.
Today there is a single figure of €10,000 per calendar year covering all your cross-border sales to consumers in other member states added together. Sell €4,000 to Germany, €3,500 to France and €2,600 to Czechia and you have crossed it, even though no single country came close.
Two conditions come with it: you must be established in only one member state, and your goods must be shipped from there. Miss either and the threshold does not apply at all.
Worked example
A Polish seller shipping from Poland, €6,500 of cross-border consumer sales so far this year, running at about €1,200 a month, mostly to Germany:
- used: 65% of the threshold
- remaining: €3,500
- crossing in roughly 3 months
- before: Polish VAT at 23% · after: German VAT at 19%
On €1,000 of net sales that is €230 of VAT before and €190 after.
Crossing the threshold can make you money
The threshold is usually described as a burden, and administratively it is. But the direction of the money depends entirely on which two countries you are between.
A Polish seller charges 23% at home. Once past the threshold, sales to Germany carry 19%, to Luxembourg 17%, to Spain 21%. If your gross prices stay the same, every one of those is more net revenue for you — four percentage points on the German market alone.
It runs the other way too. A Luxembourg seller at 17% selling into Hungary at 27% loses ten points the moment the threshold is passed. That is worth knowing before it happens, not after.
You may also opt into destination rates voluntarily before reaching the threshold. If the arithmetic above is in your favour, that is a real decision rather than a formality.
When the threshold does not help you at all
If you store goods in more than one member state, the threshold is irrelevant. Holding stock in a country creates a VAT registration obligation there from the first item, regardless of turnover.
This catches sellers who join Pan-European FBA without reading what it does: the programme moves your inventory to warehouses across several countries to shorten delivery times, and each of those countries then expects a local registration. The faster delivery is real; so is the accountant’s invoice.
OSS does not cover this. It handles VAT on cross-border sales, not the obligations that come from holding stock.
What counts toward the threshold
Counts: goods sold to private consumers in other EU member states and shipped there from your own country, plus telecommunications, broadcasting and electronic services supplied to consumers in other member states. Both go into the same €10,000.
Does not count: domestic sales in your own country, sales to VAT-registered businesses under the reverse charge, exports outside the EU, and goods dispatched from a warehouse in another member state.
Use net figures throughout. The threshold is measured excluding VAT.
What happens after you cross it
Destination rates apply from the transaction that takes you over — not from the following month or the next quarter. The sale that crosses the line is already taxed at the customer’s rate.
You then have two options. Register for VAT in every country you sell to, or register once for the One Stop Shop and declare all of it through a single quarterly return in your own country. For almost every small seller the second is the obvious choice.
Once exceeded, the destination rules bind you for the rest of the current calendar year and the whole of the next one, even if your sales fall back.
Frequently asked questions
In total. It is a single EU-wide figure covering all your cross-border consumer sales combined. The old per-country thresholds of €35,000 and €100,000 were abolished in 2021.
No. Only sales to consumers in other member states. Whatever you sell inside your own country is irrelevant to this calculation, however large.
No. Sales to VAT-registered businesses in other member states fall under the reverse charge and sit outside the threshold entirely.
Yes, voluntarily. It is worth doing when the destination rates are lower than your own — a Polish or Hungarian seller shipping mainly to Germany or Luxembourg gains on every order. The choice binds you for two calendar years.
For cross-border sales, yes — that is the point of it. It does not remove obligations that arise from storing goods abroad, which is a separate trigger and the most common reason sellers end up registered somewhere they did not expect.