Non-Union OSS – non-EU VAT OSS procedure for companies outside the EU
One country of identification can handle VAT on eligible B2C services across the EU.
The company cannot have its registered office or permanent establishment in the EU. The procedure does not cover goods, so a single non-EU company may need a Non-Union OSS, Union OSS, or IOSS in parallel.
Transaction type selects procedure
Who can use the non-EU procedure?
The actual establishment of the company, the type of recipient, and the place of taxation of the service are all important factors. A foreign VAT number alone does not determine the outcome.
Headquarters outside the EU
The taxpayer does not have its registered office in the European Union.
No permanent seat in the EU
The company does not have resources in an EU country that would constitute a permanent establishment.
B2C service taxed in the EU
The recipient is the consumer and the place of supply rule indicates an EU country.
"The company has a VAT DE, so it cannot use the Non-Union OSS." A registration number alone does not constitute a fixed establishment. A warehouse also requires an analysis of resources and functions, not automatic qualification.
What services does Non-Union OSS cover?
From 1 July 2021, the procedure is not limited to digital services. It also covers B2C services that are supplied within the EU, always subject to the application of the applicable place of taxation rule.
Not every service for an EU customer has VAT in the customer's country
A standard B2C rule may specify that the service provider's country is outside the EU. Only a special provision may shift taxation to an EU country.
Most often, they require the location of the consumer and evidence of his or her location.
The rule depends on the nature of the service and the method of participation.
The country of taxation may result from the location of the property or the route of transport.
Detailed rules are described in the VAT OSS guide for B2C services.
How to choose your country of identification?
A company meeting the Non-Union OSS requirements can choose any EU country. It does not require customers or a national VAT number.
No registered office or permanent place in the EU
The choice is not related to establishment in the EU, as the company cannot have one.
Poland as a single point of service
Poland can simultaneously be a country of identification and a country of consumption for Polish customers.
Non-Union OSS against the background of Union OSS and IOSS
The table separates procedures by company establishment and subject of transaction. It does not replace detailed qualification of services or imports.
| Element | Non-Union OSS | Union OSS – Services | Union OSS – Goods | IOSS |
|---|---|---|---|---|
| Establishment | No registered office or permanent place in the EU | Headquarters or permanent establishment in the EU | EU supplier or specific non-EU supplier | EU or non-EU supplier |
| Item | B2C services taxed in the EU | Selected B2C services provided cross-border | WSTO and selected platform deliveries | Imported goods in shipments up to 150 EUR |
| State of identification | Any EU country | Country of residence or permanent place of business | Dependent on establishment or commencement of shipment | Depends on the establishment and intermediary |
| Number and declaration | EU number, VIN-DO | National number, VIU-DO | National number, VIU-DO | IM number, VII-DO |
| Period | Quarter | Quarter | Quarter | Month |
| Example | US Software for the FR Consumer | Service from a Polish company for a DE consumer | DE product → FR consumer | CN goods → FR consumer, 120 EUR |
For a broader distinction between procedures, see the OSS vs. IOSS guide .
VIN-R, VIN-DO and special EU number
The non-EU procedure uses different forms than the EU procedure. Please do not interchange VIN and VIU references.
Notification of information regarding a specific non-EU procedure.
VAT return covering eligible services in the countries of consumption.
The number is for Non-Union OSS use only. It is not a regular national VAT ID or VIES number.
How long has registration been open?
The standard start date and the first sale exception lead to different entry dates. This structure is confirmed by the European Commission's OSS registration rules.
The company informs the selected identification country of its intention to use the procedure.
This is the standard registration effectiveness date.
The procedure may cover sales earlier than the beginning of the next quarter.
Being late could leave early sales to local responsibility.
Declarations, payments and VAT on costs
VIN-DO aggregates VAT due by country of consumption. It is not a declaration for deducting tax from cost invoices.
Covers all eligible services in the country of consumption, including services taxed in the country of identification.
A declaration is also submitted for the period without qualifying services.
Input VAT is recovered locally or through the appropriate refund procedure.
What if a permanent establishment is established in the EU?
The creation of a permanent establishment means that the company no longer meets the basic condition of the non-EU procedure.
No registered office or permanent place in the EU
Eligible B2C services can be billed to Non-Union OSS.
Possible transition to Union OSS
With one fixed location, its country influences the country of identification. With multiple locations, selection rules apply.
A US company chooses Poland as its country of identification
One declaration does not mean one rate. Each service must be assigned to the appropriate country of consumption and place of supply rule.
Three services, three distinct qualifications
Poland processes the declaration, but the tax must be distributed among the countries of consumption.
Check for evidence of location and the French rate applicable to the service.
VAT in FranceThe sale goes to the German basket at VIN-DO.
VAT in GermanyFirst, establish a rule for the event; Poland can be a country of identification and consumption at the same time.
VAT in PolandYou choose the rate depending on the service and country
The EU number and country of identification do not standardize rates. You apply the rate appropriate for the specific service in the country of consumption.
Non-Union OSS Checklist
Go through the terms, transactions, documents and deadlines before selecting your country of identification.
First, the establishment and place of performance
The customer's country, store domain or VAT number alone are not sufficient to select the procedure.
- The registered office of the company is located outside the EU
- No permanent establishment in the EU
- List of all EU VAT numbers
- Type of each service provided
- B2C recipient status
- Place of supply rule
- State of consumption
- Selecting the country of identification
- VIN-R form and signature method
- Special EU number
- Date of First Qualifying Service
- Deadline: 10th of the following month
- Rates by country and service
- Quarterly VIN-DO declaration
- Zero declarations
- The path to recovering VAT on costs
- Monitoring changes to company establishment
A company outside the EU provides services to consumers?
We help you separate services covered by Non-Union OSS from sales of goods, select the country of identification and prepare data for quarterly settlements.
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Select next topic
All guides are organized by topic. Select a title on the left to see a brief explanation and link on the right.
VAT OSS
General guide to One Stop Shop procedures.
Read the guideVAT OSS registration
VIU-R form and entry into the EU procedure.
Read the guideVIU-DO
Quarterly declaration of the EU OSS procedure.
Read the guideOSS VAT Limit
Threshold of €10,000 for ESPO and selected services.
Read the guideWSTO and VAT OSS
Terms and conditions for distance selling of goods in the EU.
Read the guideOSS or local VAT
Situations where OSS simplification is not enough.
Read the guideVAT OSS and Amazon FBA
Foreign warehouses, STO and local responsibilities.
Read the guideVAT OSS in dropshipping
Supply chain, OSS, IOSS and local VAT.
Read the guideVAT OSS for B2C services
Place of provision and scope of services covered by OSS.
Read the guideVAT OSS and the sales platform
When a platform becomes an established supplier.
Read the guideOSS and IOSS
Differences between procedures for goods and services.
Read the guideSME procedure and VAT OSS
Small business exemption and OSS taxation.
Read the guideOSS VAT records
Scope of data stored for ten years.
Read the guideInvoices, KSeF, JPK and cash register
Sales documentation relationship to OSS settlement.
Read the guideDeregistration from VAT OSS
Resignation and change of country of identification.
Read the guideExclusion from VAT OSS
Reasons for exclusion and re-registration.
Read the guideOSS VAT audit and penalties
Data control, arrears and remediation obligations.
Read the guideVAT charged at OSS
Recovering foreign VAT from costs.
Read the guideVAT OSS and INTRASTAT
Relation of VAT settlement to freight traffic.
Read the guideVAT OSS and B2B sales
WDT, WNT, reverse charge and customer status.
Read the guideVAT OSS correction
Returns, discounts and errors in the later VIU-DO.
Read the guideNon-Union OSS
B2C services provided in the EU by a company without a registered office or permanent establishment in the EU.
Read the guideFixed establishment and VAT OSS
The impact of resources in the EU on the procedure and country of identification.
Read the guideEU special territories
Areas excluded or covered by special VAT rules.
Read the guideGift cards
Settlement of single-purpose and multi-purpose vouchers.
Read the guideSort out services before your first VIN-DO
Combine the country of consumption, place of supply rule, rate, and customer location evidence before you close the first quarter.
Non-Union OSS Questions and Answers
No. The non-EU scheme covers eligible B2C services taxed in the EU. Goods may be subject to Union OSS, IOSS, or local settlement.
Yes, if it has no registered office or fixed establishment in the EU and provides qualifying B2C services taxed in the EU.
Not in and of itself. A VAT number does not establish a registered office or permanent establishment. The actual resources and methods of operation of the company within the EU must be investigated.
Yes. A taxpayer meeting the Non-Union OSS conditions may choose any EU country as their country of identification.
No. This is a special non-Union procedure identifier used for Non-Union OSS settlements. It should not be presented as a regular VIES number.
Quarterly, by the end of the month following the given quarter. A declaration is also submitted if no qualifying services were provided during the period.
No. VIN-DO is used to settle VAT due. Tax on costs is recovered through the appropriate refund procedure or local declaration, depending on the situation.
Not automatically. First, you must determine the nature of the service, the status of the recipient, and the place of supply in accordance with the applicable VAT rules.
