What is a Fiscal Representative? 

A fiscal representative is a locally appointed business or individual that is typically jointly liable for any Value Added Tax (VAT) owed by a non-EU taxpayer.

Some European countries require foreign businesses to appoint a fiscal representative before they can register for VAT. Generally, it’s a requirement of EU (European Union) Member States, but in some cases, Norway calls for it too.  

Fiscal representatives can be tax consultants or agents, auditors, lawyers or accountants. They can support foreign companies importing into Europe.   

Some countries offer two options for fiscal representation: general or limited. The difference is generally the amount of liability and responsibilities involved.   

General Fiscal Representative  

With general authorisation, fiscal representatives act on behalf of foreign businesses regarding VAT on: 

• The sale of goods and services
• Any acquisitions made between EU Member States
• Imports 

They’re jointly liable for any VAT, import duties or extraneous fees included in the sale of goods or services by that business. To use general fiscal representation, you have to be VAT registered in the country you’re selling to. 

When appointing a tax representative, you’ll usually need to settle either a bank guarantee or pay a cash deposit. Depending on the country, the guarantee/deposit is cleared by either the fiscal representative themselves or the tax authority. The amount requested will depend on different factors such as:  

• Your annual turnover
• The number of invoices you generate in a period

In some very specific cases, you might be able to negotiate the amount. 

Limited fiscal representative  

With a limited authorisation, fiscal representatives act on behalf of foreign businesses regarding VAT on:   

• The importation of goods
• The supply of zero-rated goods
• Intra-EU acquisition of goods

You might not need to be registered in the country you’re selling to with limited representation. You’d assume the agent's VAT number for the purpose of importing or moving goods. 

What does a fiscal representative do?  

Once you have a fiscal representative, they’re equally liable for VAT due on the sale of your goods. This means that they’re responsible for ensuring you follow VAT rules. For example, if you miss a VAT payment, the tax authority will go to them for the amount you owe. 

It’s more than just the money, however. As appointed VAT proxies, they are responsible for ensuring you stay compliant. They’re obligated to: 

• Ensure your business is fully registered with the relevant tax authority
• Maintain the compliance of any invoices, VAT returns, VAT rate application and conversion rates
• Handle VAT returns, Intrastat declarations and EC Sales Lists
• Keep ample records that abide by the specific country’s standards
• Handle any duties, fines or penalties associated with the importation of goods 

In some cases, they can help you acquire an EORI number.

The joint liability means that, usually, a contract with a fiscal representative will have some serious conditions: 

• Fines and Penalties if you miss a deadline (in our experience, they can be steep)
• Long contact periods (we find they’re usually for a year)
• Detailed record keeping on your part 

If you stop needing their services halfway through a contract period, you’ll probably have to keep paying until it ends. 

Do I need a fiscal representative?  

Whether you need a tax representative depends on two things: 

• The country you’re selling to
• The country where you’re based 

Generally, businesses based in the EU don’t need fiscal representation to export to other EU countries or Norway. However, it can make navigating particularly complex tax systems easier, especially if you don’t speak the language. 

If you’re based outside the EU and providing taxable goods or services, appointing a representative is often not optional. 

Which countries require a fiscal representative?  

Below is our list of countries and whether they require non-EU businesses to use a Fiscal Representative. 

The country that you’re established in may have signed a Tax Mutual Assistance Agreement with the country you want to sell to. If that’s the case, you might not need to appoint a fiscal representative, depending on the conditions of the agreement. 

Information below is correct as of 20^th of August, 2025.

You used to need a fiscal representative in Switzerland, but the requirement was altered in January 2025. Now, you can register for VAT directly with the Swiss Tax Authority, but only if you meet certain conditions. Namely, you have to be able to guarantee compliance and communication with the authorities. 

What happens if I don’t have a fiscal representative? 

Not appointing a fiscal representative when you’re supposed to can lead to penalties. You also won’t be able to get a VAT refund if you’re found to be trading without having appointed one. 

Overall, this can harm your ability to do business in Europe. Many manufacturers, marketplaces and customers will decline to work with you if you’ve broken local law. In some cases, working with you whilst your business is non-compliant can cause problems for them as well. 

Additionally, your VAT registration application is likely to be rejected if you don’t appoint a compliance partner when necessary. That’s your time and money wasted on that application, and more trading delays whilst you apply again. 

Why is appointing a fiscal representative beneficial? 

The primary reason to appoint a fiscal representative is to avoid penalties, particularly as a non-EU business. However, they can help improve your cash flow by: 

• Relieving you of the administrative burden of import VAT and customs processes
• Speeding up the process for reclaiming import VAT when you import to one EU state and sell to another
• Help you implement the reverse charge mechanism, where it applies
• Allowing you to take advantage of certain cash flow simplifications by applying for specific import licenses (depending on the country)

Local VAT representatives are also experts in their country’s tax system and speak the language. In countries where the tax office only communicates in the local language, that’s hugely helpful.   

Do I need a fiscal representative to register for IOSS? 

The Import One Stop Shop (IOSS) scheme doesn’t require you to have a fiscal representative. Instead, you need an IOSS intermediary. Intermediaries are similar to fiscal representatives: 

• Both act on behalf of non-EU businesses to handle VAT
• Both are required when a non-EU business doesn’t have a legal presence in the EU, but wants to comply with VAT rules
• Both are jointly liable for VAT reporting and payments 

The key difference is that an intermediary is limited to handling the VAT covered by IOSS. Fiscal representatives can support you with general VAT compliance for all kinds of sales. Businesses based outside the EU can easily have both an intermediary and a fiscal representative. 

When you register for IOSS, you’ll be registered for the scheme in the country where the intermediary is registered. For example, if you register for IOSS with SimplyVAT, you’d be registered for IOSS in Ireland. Once you’re registered, we compile and file your returns with the Irish Tax Authority.

This blog was originally published October 22nd 2022, and has since been updated for comprehensiveness.