Over the last couple of days, Belgium has approached UK entities having a Belgian VAT registration number to appoint a fiscal representative. This would indeed be needed in case the UK leaves the European Union and UK entities become non-EU established entities (scheduled still for 31 December 2020).
However, many other EU countries require non-EU entities to appoint a fiscal representative.
Country | Fiscal rep for non-EU companies | Fiscal rep for EU companies |
Austria | Required | Optional |
Belgium | Required | Not required |
Bulgaria | Required (unless there is a legal instruments for mutual assistance) | Optional |
Croatia | Required | Optional |
Cyprus | Required (unless bank guarantee is deposited with the tax authorities) | Optional |
Czech Republic | Not possible | Not possible |
Denmark | Required – Optional for Norway, Greenland, Iceland and the Faroe Islands | Optional |
Estonia | Optional | Optional |
Finland | Required (Optional in case treaty has been concluded concerning mutual assistance by the competent authorities as regards indirect taxes) | Optional |
France | Required (Optional in case treaty has been concluded concerning mutual assistance by the competent authorities as regards indirect taxes) – France has indicated unofficially that UK business would need to have a fiscal representative in the UK – to be confirmed | Optional |
Germany | Optional | Optional |
Greece | Optional | Optional |
Hungary | Required | Optional |
Ireland | Not required – not possible | Not required – not possible |
Italy | Required (Optional in case treaty has been concluded concerning mutual assistance by the competent authorities as regards indirect taxes) | Optional |
Latvia | Optional | Optional |
Lithuania | Required | Optional |
Luxembourg | Optional | Optional |
Malta | Optional | Optional |
Netherlands | Optional (Required for a limited number of transactions) | Optional (Required for a limited number of transactions) |
Poland | Required | Optional |
Portugal | Required | Optional |
Romania | Required | Optional |
Slovakia | Not required (possible in limited cases) | Not required (possible in limited cases) |
Slovenia | Required | Optional |
Spain | Required | Optional |
Sweden | Required (Optional in case treaty has been concluded concerning mutual assistance by the competent authorities as regards indirect taxes) | Optional |
United Kingdom (until Brexit) | Required (Optional in case treaty has been concluded concerning mutual assistance by the competent authorities as regards indirect taxes) | Optional |