The One-Stop Shop lets you report the VAT due across all 27 EU member states through a single return, filed in one country, rather than registering separately in each one. It is divided into two schemes, and which of them applies to your business depends on where that business is established and on whether you are supplying goods or services.
Businesses established in the EU use Union OSS. Businesses established outside it use Non-Union OSS for their services, and Union OSS for goods that are already inside the EU when they are sold. If you are outside the EU and supplying both, you will need to register for both.
At Nathan Trust, we register international companies for Irish and EU VAT and handle the quarterly filings that follow. Most of the businesses we work with are selling into the EU for the first time, and they nearly always arrive with the same two questions: which scheme, and which country?
| Your Situation | Scheme | Where you register | Returns |
| Established in Ireland, selling goods or services to consumers in other EU countries | Union OSS | Ireland, and only Ireland | Quarterly |
| Established in another EU country | Union OSS | Your home country | Quarterly |
| Not established in the EU, selling goods that are already inside the EU | Union OSS | Where the goods are dispatched from | Quarterly |
| Not established in the EU, selling services to EU consumers | Non-Union OSS | Any EU country you choose | Quarterly |
| Not established in the EU, selling both goods and services | Both schemes | Separately, see below | Quarterly, each |
| Shipping goods into the EU in consignments of €150 or less | IOSS, not OSS | Ireland; non-EU sellers need an intermediary | Monthly |
Union OSS covers two things: intra-EU distance sales of goods, and B2C services supplied in a member state where you are not established. If your business is established in the EU you can use it for both. If it is established outside the EU you can use it for goods only, and only where those goods are already inside the EU at the point of sale.
Where you register is not a free choice. If your business is established in Ireland, Ireland is the only member state you can register in. If it is established outside the EU with a fixed establishment here and nowhere else in the union, you are obliged to register in Ireland, and where you hold fixed establishments in more than one member state you may choose between them. If it is established outside the EU with no fixed establishment anywhere in the union, you register in the member state your goods are dispatched from, and again, where they are dispatched from more than one is your choice.
Either binds you for the rest of the calendar year in which you make it and for the two calendar years after that. [2] A US seller who registers in Ireland in March 2026 will be filing through Ireland until the end of December 2028, whatever happens to its supply chain in the meantime.
That is a three-year commitment made at the point of registration, usually before anyone has thought about where the business will be shipping from in 2028. It's worth an hour of advice before you file. We prefer to work through the likely shape of a client's EU operation before picking the country, rather than the other way round.
Non-Union OSS applies to businesses with no establishment and no fixed establishment anywhere in the EU, supplying services to EU consumers.
Its scope is wider than it used to be. Under the Mini One-Stop Shop the scheme reached digital services only. Since 1 July 2021 it has covered all B2C services supplied to EU consumers, which takes in consultancy work, online training, admission to events and software.
Registration is less constrained than under the Union scheme. You can select any member state as your country of identification, and it will issue you a scheme number in the format EUxxxyyyyyz. The same binding period applies: the year you make the choice in, and the two after it.
If your business is established outside the EU and you sell goods from EU stock as well as supplying services to EU consumers, you are not choosing between the two schemes but are required to have both.
Union OSS covers the goods and is registered in the member state those goods are dispatched from. Non-Union OSS covers the services and can be registered anywhere. That means you need two separate registrations with each carrying its own quarterly return and its own records.
We see this most often with software companies that also ship hardware from a European warehouse, and with any business whose supply is genuinely mixed. Nathan Trust runs both registrations together for clients in that position, on a single set of deadlines so the two returns don't drift apart.
There is an EU-wide threshold of €10,000 a year that allows some businesses to keep charging their home country's VAT rate on cross-border B2C sales rather than registering for OSS at all.
The conditions attached to it are narrow. You qualify only if your business is established in one member state and nowhere else, and only if the goods are dispatched from that same member state. The €10,000 is a single running total covering intra-EU distance sales of goods together with telecommunications, broadcasting and electronic services, and it does not apply per country of destination.
So the threshold is closed to any business established outside the EU. It is equally closed to a business holding stock in more than one member state, whatever its sales volume. If you are a US or UK company, your OSS obligations begin with the first sale.
A US company selling kitchenware holds stock in a third-party warehouse outside Rotterdam, ships to consumers in Ireland, Germany, France and Spain, and also sells an online cooking course to those same customers.
The kitchenware is already inside the EU when it is sold, which makes those transactions intra-EU distance sales reported through Union OSS. The company has no fixed establishment in the EU, so the Netherlands becomes its country of identification, because that is where the goods are dispatched from. No threshold is available to it, so Union OSS applies from the first order.
The cooking course is a service supplied by a business established outside the EU, so it falls under Non-Union OSS. Here the company can choose which member state to register in.
Then there is the warehouse. Holding stock in the Netherlands requires a Dutch VAT registration covering the stock movements, and any sale shipped from Rotterdam to a Dutch consumer is a domestic Dutch supply that belongs on a Dutch VAT return rather than in an OSS one. That leaves the company holding three separate registrations, only two of which OSS addresses.
A Manchester clothing brand ships from the UK to consumers across the EU, with a typical order value of £60 to £90.
None of this is an OSS supply. The goods are being imported into the EU in consignments below €150, which puts them within IOSS rather than either OSS scheme, and a business established outside the EU using IOSS has to appoint an intermediary established in the EU.
Should the company later move stock into an Irish or Dutch warehouse and ship from there, the position changes. Those sales become intra-EU distance sales falling under Union OSS, and the country of identification becomes whichever state the goods are then dispatched from. Adding a subscription service for EU customers would bring Non-Union OSS into the picture as well.
The scheme that applies follows the physical movement of the goods rather than the structure of the company, which is why the answer changes when a warehouse moves. Our tax team maps this out for clients before they commit to a fulfilment arrangement, because the VAT consequences of that decision are easier to plan for than to unwind.
OSS removes the VAT registrations created by cross-border B2C selling. It does not remove the ones created by anything else.
B2B supplies fall outside it and are generally handled through the reverse charge. Domestic sales made from stock held in a country belong on that country's local VAT return, and movements of your own stock between member states carry obligations of their own, at least until the 2028 reforms set out below. Imports in consignments of €150 or less are dealt with through IOSS, and imports above that follow normal import VAT and customs rules, with postponed accounting available in Ireland.
Businesses holding stock across several member states, which includes most sellers using Amazon's European fulfilment network, will generally end up running OSS and local registrations side by side.
Businesses established in Ireland register through the VAT OSS section of ROS, while suppliers established outside the EU register through the non-Union portal, or through ROS if they already hold another OSS registration here.
Registration normally takes effect on the first day of the calendar quarter after you notify Revenue.
There is an exception where supplies have already begun, and it is the one to watch. If you have started making supplies covered by the scheme, you must notify Revenue by the 10th day of the month following the month that first supply took place, and if that date passes you are required to register for VAT and account for it directly in every member state where you made sales, for the whole period before your OSS registration takes effect. [2] A single Irish return becomes separate registrations and returns in each member state of consumption.
This is the deadline we most often find has already been missed by the time a business comes to us, usually because nobody realised the clock started with the first sale rather than with the decision to register.
Returns are quarterly, filed electronically by the end of the month after the quarter closes. Payment falls due on the same date. A quarter in which you made no sales still needs a return, filed as a nil return.
Corrections work differently from a standard VAT return. You cannot amend a return you have already submitted. The correction goes into the correction panel on a later return instead, identifying the member state of consumption, the period concerned and the amount of VAT, and you have three years from the date of the original return to make it. [2]
Records have to be kept for 10 years from 31 December of the year the transaction was carried out, and provided electronically if Revenue or any member state of consumption asks for them.
Nathan Trust files OSS returns for clients as part of our ongoing VAT compliance work, alongside Irish VAT3 returns, the annual RTD and VIES returns where they apply. If you would rather hold the filings in-house, we will set the registration up and hand you a calendar of the deadlines that attach to it.
Revenue will remove a business from the Union scheme for persistent failure to comply, and it defines that in specific terms: three return periods where a reminder has been issued and the return still has not been filed within 10 days of it, or three periods where a reminder has been issued and the payment still has not been made.
Exclusion is not confined to the scheme you fell behind on. A business excluded for persistent non-compliance is excluded from Union OSS, Non-Union OSS and IOSS, in every member state, for two years. For that whole period it has to register and file individually in each member state where it makes supplies, which is the position OSS exists to prevent.
The VAT in the Digital Age package extends OSS in two stages. From 1 July 2027 the scheme takes in supplies of gas, electricity, heating and cooling. From 1 July 2028 it widens considerably, to cover all B2C services supplied in member states where the supplier is not established, goods supplied with installation, and movements of a business's own stock between member states, and from that same date no new call-off stock arrangement can be started, with transitional rules for the existing ones running until 30 June 2029.
If you are currently carrying three local VAT registrations solely because you hold stock in three member states, the 2028 change is the one to plan around. We are already factoring it into structuring advice for clients building out EU fulfilment now, since arrangements put in place this year will still be running when it lands.
Which scheme applies to your business comes down to five things: where the business is established, whether you are supplying goods or services, where your stock is physically held, whether your customers are consumers or businesses, and whether any consignment crosses an EU border at €150 or less.
Tell us how your goods move and who's buying them, and we'll set out which registrations apply to you, in which member states, and what each one involves. Our tax team has been handling Irish and EU VAT for international companies since 1999, and you'll have the same consultant from the first conversation through to your first filed return.