Single VAT Registration 2028 – is one VAT number in the EU enough?
Single VAT Registration does not mean a single VAT number for the entire European Union.
However, from 1 July 2028, TOOG, the extended Union OSS and mandatory reverse charge could significantly reduce the number of local VAT registrations – if the specific model meets the conditions of each mechanism.
One name, three different ways to limit VAT registration
The official European Commission timetable indicates 1 July 2028 as the start date for the main reforms of Single VAT Registration and mandatory reverse charge for locally unidentified suppliers.
“From 2028, I will have a single VAT number valid throughout the EU.”
The SVR does not create a single EU VAT ID.
This limits the need for another local registration. Each existing number must be assessed based on the reason for having it.
Shortest correct answer: One trader may need fewer local VAT numbers, but will not receive one universal number for all transactions in the EU.
How does TOOG, OSS and reverse charge form Single VAT Registration?
Each mechanism addresses a different potential cause of local VAT registration.
REGISTRATION simplification system
A qualifying movement may enter the TOOG and remove the registration resulting from its corresponding WNT.
See TOOG rulesExtended Union OSS may cover certain domestic deliveries from warehouse to consumer.
Compare OSS and local VATA mandatory reverse charge can transfer settlement to a locally identified buyer, but only if conditions are met.
Check the key conditionWhy does e-commerce need multiple VAT numbers today?
The mere fact that a company does not sell goods during transfer to a warehouse does not eliminate the current VAT implications. Recital 42 of Council Directive (EU) 2025/516 indicates that the transfer of own goods – including for e-commerce – now leads to registration in the countries from and to which the goods are transferred.
Currently, it can mean IDT of own goods in Poland and INT of own goods in Germany.
Local B2C or B2B sales create another layer of responsibility. Therefore, simply analyzing Polish-German transport is not enough.
The current rules for the transfer of stock are explained in the guide on the movement of goods abroad – IDT and INT of own goods.
Warehouse in Germany: today and from July 1, 2028.
The diagram below shows a model that qualifies for simplification. It's not a rule for every warehouse.
- Own stock PL → DE
- WNT in Germany
- VAT ID DE
- Local B2C sales DE → DE
- Local VAT declaration DE
- Own stock PL → DE
- TOOG
- DE Magazine
- B2C DE → DE
- Union OSS
Alternative B2B leg: sales from a DE warehouse to a DE VAT company may lead to a mandatory reverse charge if the conditions of Article 194 are met.
Important: The scheme applies to eligible models. Imports, local purchases, activities outside the scope of the regulations, or permanent establishment status may still justify local VAT registration.
Why do you have a foreign VAT number?
Select the main reason for registration. The module indicates the area to be checked – it does not make decisions about deregistration.
First, choose the cause
Don't start by asking, "Can I close my VAT DE?" First, determine why this number was obtained and what transactions it covers.
Go to VAT ID auditWill a local VAT ID be needed after 2028?
The answer requires traversing all three layers. Stopping the analysis after TOOG alone can lead to an incorrect decision.
Where does the goods move?
If your own stock is moving to another EU country, check your TOOG.
Separately assess transfers excluded from the procedure and goods without full right of deduction.
Who are you selling to?
Local sales to a consumer may require analysis of the extended Union OSS.
Local sales to a company with a VAT ID lead to an analysis of Article 194 and reverse charge.
What else are you doing in this country?
Check imports, purchases, other supplies, services, local VAT charged and permanent establishment status.
Only then can the need to maintain the number be assessed.
What exactly can each SVR element take over?
Single VAT Registration works when the right tool fits the specific activity.
A special procedure may eliminate the registration requirement arising from qualifying ITC of own goods. Reporting and record-keeping are discussed in a separate guide.
TOOG Declaration and RecordsThe new Article 369b of the VAT Directive extends the procedure to, among others, certain domestic supplies of goods made by a taxable person not established in the taxing country.
It can transfer the VAT liability to the locally identified buyer. However, it should not be automatically applied to every B2B sale.
Check Article 194 of the VAT DirectiveThe basic, mandatory reverse charge under the new Article 194 applies to situations where the supplier is not established and is not identified by an individual VAT number in the taxing country, but the purchaser is identified there. Member States may also provide broader national solutions for non-established taxpayers.
Single VAT Registration with Amazon FBA and Multiple Warehouses
In the Pan-European FBA model, the number of warehousing countries does not automatically translate to the same number of registrations after 2028. However, it is still necessary to know each relocation and each subsequent transaction.
Every relocation
May be a separate transfer of own goods requiring TOOG qualification.
Any type of sale
B2C, B2B and cross-border sales may require different billing methods.
Every country
You also need to check imports, other activities and local reverse charge rules.
The context of the current model is described in the article VAT OSS, Amazon FBA and overseas warehouses.
How can I check if a foreign VAT number will still be needed?
For each VAT ID, create a cause map. The "requires further analysis" result is correct – the table should not automatically trigger a deregistration decision.
See how Single VAT Registration connects with other ViDA changes
Check out the schedule, e-commerce impact, and all the articles from the 2028 cluster.
Do not automatically deregister foreign VAT on July 1, 2028.
Existing numbers will not disappear with the implementation of the reform. First, you must confirm that each obligation settled by a given VAT ID has been taken over by the appropriate mechanism or has ceased to exist.
Permanent place of business
The mere fact of being based in Poland does not mean that the company is not established in any other country for the purposes of OSS or reverse charge.
Recovery of input VAT
Fewer local declarations mean the need to determine how the company will recover VAT on local costs once registration is closed.
Imports and transactions outside the procedures
If at least one activity still requires a local VAT ID, the number may remain required regardless of TOOG and OSS.
If you are analyzing the current situation, start with the VAT OSS or VAT registration abroad.
Is your company ready for a Single VAT Registration audit?
Select the information you can collect today for all countries. The result indicates the completeness of the map, not approval for closing the VAT number.
Information collected: 0 out of 10
Check which VAT numbers may become redundant and which will still be needed
We will analyze warehousing, transfers, B2C and B2B sales, imports, input VAT, and other local activities. The result will be a map of obligations for each country – not an automatic recommendation for deregistration.
Frequently asked questions about Single VAT Registration 2028
What is Single VAT Registration?
This is a pillar of the ViDA package, which combines extended OSS, TOOG procedure and mandatory reverse charge to reduce the need for multiple local VAT registrations.
Will there be one VAT number for the entire EU from 2028?
No. The reform does not create a single European VAT number. However, it may eliminate some of the reasons why companies currently have multiple local numbers.
When will the major SVR changes take effect?
The main elements of Single VAT Registration are to be applied from 1 July 2028.
Will a foreign warehouse still require a VAT ID?
This cannot be assessed solely based on storage location. Inventory transfer, subsequent sale, and other local activities must be examined.
What role does TOOG play in SVR?
TOOG may remove the registration obligation arising from the qualifying ITC of own goods in the destination country.
Will local B2C sales from the warehouse be able to be settled via OSS?
From 1 July 2028, the extended Union OSS is to cover certain domestic B2C supplies made by taxpayers not established in the taxing country.
Will all local B2B sales be subject to reverse charge?
No. The basic Article 194 requires, among other things, the absence of an established and local individual VAT ID for the supplier and identification of the purchaser in that country.
Can foreign VAT be automatically deregistered on 1 July 2028?
No. First, you need to determine all the reasons for having the number, the transactions that are not covered by simplifications, and the method of recovering input VAT.
Does Single VAT Registration apply to Amazon FBA?
Such models may particularly benefit from the reform, but each relocation and each type of subsequent sale still requires separate qualification.
Don't ask first how many VAT numbers you can close
First, determine what obligations each number covers today and which ViDA element could replace them from July 1, 2028.
