When importing goods into the EU, standard rules typically require an immediate payment of roughly 21% import VAT at the border. For a shipment valued at €100,000, this freezes €21,000 in liquid capital before you have sold a single unit of stock.
The Netherlands offers the Article 23 license (or Artikel 23 vergunning), a mechanism that shifts this tax from a cash payment to a simple bookkeeping entry on your periodic VAT return. While several countries have introduced similar mechanisms for 2025, the Netherlands remains the most mature and service-dense gateway for global importers.
Requirements & The “Virtual Office” Trap
One of the most common mistakes is assuming a “virtual office” or mailbox address is enough to secure a license.
- Substance Requirements: To apply for a license directly, a company must have a “fixed establishment” in the Netherlands. This means more than just a paper address but actual substance; the tax authorities (Belastingdienst) look for local management, physical workspace, and decision-making staff.
- Virtual Office alone is insufficient: Attempting to use a “letterbox” address with no real commercial activity will lead to an immediate rejection of your Article 23 application.
- The Solution (Fiscal Rep): For non-EU businesses and foreign EU companies without physical Dutch substance, the Fiscal Representative pathway is the standard requirement. The representative provides the necessary legal presence and handles all liability on your behalf.
Rotterdam as a “Virtual” Free Zone
While the Netherlands is not listed on the official EU registry of physical “Free Zones,” it utilizes a superior administrative system that the EU Commission’s website “de facto free zone”.
- Virtual Freedom: In geofenced “Official Free Zones” (like those in Spain), tax benefits are lost if goods leave a specific physical district. In the Netherlands, the “zone” travels with the goods. You can move stock to any of the 60+ licensed bonded warehouses across the country while enjoying full tax suspension.
- Ecosystem Scale: Rotterdam is Europe’s largest port, backed by a massive ecosystem of 3PL providers experienced in English-language Dutch VAT deferral workflows.
Northern & Western Europe Comparison (2026)
| Country | Mechanism | Setup Timeline | 2026 Requirement | Best For |
| Netherlands | Article 23 | 6–10 Weeks | License Required; often waived guarantee via Fiscal Reps. | EU-wide Distribution |
| Germany | Postponed Acct | 8–12 Weeks | New for 2025; historical guarantee often required. | DACH Region / Solar PV |
| France | Auto-Reverse Charge | 6–10 Weeks | Mandatory & Automatic for all VAT-registered firms. | Direct French Sales |
| Belgium | ET 14000 | 4–8 Weeks | 10% Guarantee typically required for new importers. | Transit to France/UK |
| Denmark | Import VAT Suspension | 8–12 Weeks | Mandatory Fiscal Rep for non-EU. | Nordic Market Focus |
| Sweden | Uppskov med moms | 6–10 Weeks | Jointly Liable Fiscal Rep for non-EU. | Scandinavian Logistics |
| Ireland | Postponed Acct | 8–10 Weeks | Automatic for VAT and Customs registered traders. | US/UK Entry; Tech & Pharma |
When NOT to Use the Netherlands
While the Netherlands is a powerful hub, specific 2025 market shifts mean other countries may be more optimal in certain scenarios:
- DACH Region Dominance (Germany Focus): If 80%+ of your customers are in Germany, Austria, or Switzerland, use Germany’s new 2025 postponed accounting system. This avoids unnecessary cross-border trucking costs from Rotterdam and allows you to utilize Hamburg’s massive rail network, which moves 2M+ TEUs annually into Central Europe.
- Direct French Market Focus: If you are selling primarily to French consumers, use France’s automatic reverse-charge system.
- Note for 2026: France is abolishing the “one-off” fiscal representation model (Regime 42) for non-EU importers on December 31, 2025. From 2026, non-EU companies must have their own French VAT registration and a full fiscal representative to import through France.
- Low Volume: If importing <€50,000/year, the monthly professional fees for fiscal representation (€200–€400/month) may outweigh your cash flow savings.
If you are importing physical goods from South America to sell in Germany or Poland, your primary challenge isn’t logistics—it’s VAT cash flow. The Netherlands is the default choice because of how it handles the “import moment.”
Can I import in NL and sell in Germany?
Yes, and for bulk shipments, this is the most efficient route.
• Fiscal Representation: If your company is in the Netherlands, you use your own VAT and Article 23 license. You clear customs in Rotterdam, and then move the goods to Germany or Poland as an intra-community delivery (0% VAT).
• Distance Selling: If selling directly to consumers (B2C) across the EU, you will likely use the OSS (One-Stop Shop) system to manage VAT across different member states from your Dutch home base.
Comparison: Why not Germany or Poland?
- Germany: While a massive market, Germany does not offer a VAT deferral system as flexible as Article 23. You will often have to pay VAT upfront at the port (Hamburg/Bremerhaven) and wait months for a refund.
- Poland: Offers lower warehousing costs, but the administrative burden of customs clearance is significantly higher for non-Polish speakers, and VAT refunds can be slow.
→ Contact us to set up your Dutch BV and Article 23 import license
Logistics: The T1 Transit Document
A common misconception is that you can land goods in Hamburg (Germany) or Dublin (Ireland) and use your Dutch Article 23 license directly at that dock. This will result in an immediate tax bill.
To use Dutch VAT deferral for goods landing at a non-Dutch port:
- Open a T1 Transit Document at the port of arrival (e.g., Hamburg).
- Move the goods physically “under bond” to a bonded warehouse in the Netherlands.
- Clear Customs in the Netherlands to trigger the Article 23 deferral.
