What is Fiscal Representation?

A Fiscal Representative is an economic operator who assumes the VAT obligations of a foreign economic operator with the domestic tax authorities.

ALS operates Fiscal Representation in the following 4 countries across the EU:





Responsibilities of a Fiscal Representative

  • ALS handles customs declarations for import customs clearance
  • ALS makes advance payments and provides seamless documentation
  • Submission of VAT returns
  • Paperwork and archiving
  • Advice and support in correspondence with customs authorities
  • Checks document correctness and legal requirements
  • Maintains separate records for fiscal representation
  • Provides quarterly submission of advance VAT return
  • Provides monthly submission of recapitulative statement
  • Provides monthly submission of intra-Community trade statistics
  • Completes annual turnover tax return submission
  • Supports importation of goods from Switzerland with a customs declaration under the 42.00 procedure
  • Completes statistical declarations with the customers’ VAT number for goods delivered to another EU country
  • Provides one-off tax representations under the 42.00 regime for non-EU customers wishing to sell goods in an EU country other than France
  • Does not support representation if the customer wishes to sell goods in France or has a French VAT number
  • Offers joint and several liability for the tax debts of the company
  • Reports VAT on ALS Customs Services N.V’s VAT identification number
  • Prepares intrastat reports and submits them to the Belgian government
  • Reports VAT on ALS Customs Services B.V’s VAT identification number
  • Prepares Intrastat reports and forwards them to the Central Statistical Office (CBS)
  • Provides 3 reports: VAT report on ALS Customs Services B.V., ICL report on the VAT of EU Client, and Intrastat report for statistics

Rights of a Fiscal Representative

In Germany

  • A fiscal representative has the same rights as the representative and can submit necessary applications

In France

  • ALS is entirely responsible to the French tax authorities as an indirect representative
  • ALS requires a signed mandate from the client appointing them as a one-off tax representative

In Belgium

  • ALS obtains the right to act as a fiscal representative for the importer for the VAT obligation

In the Netherlands

  • ALS has the right to act as a fiscal representative for the importer for the VAT obligation

When is Fiscal Representation required?

Fiscal Representation is required when importing goods from a 3rd country into the EU without charging import VAT.

It is also required for example, when a non-EU customer, without a French VAT number, wishes to sell goods in any EU country other than France.

Exploring the Significance of SMEs Based in Third Countries

The term SME encompasses micro, small, and medium-sized enterprises.

  • When an SME is based in a third country, it holds a particular significance. In the specific scenario of France, ALS offers the opportunity for these third-party customers, who are not established in the EU, to sell goods within the EU without needing establishment there.
  • For instances where deliveries are conducted under the Delivery Duty Paid (DDP) incoterm, there are circumstances where Fiscal Representation can be combined with Indirect Representation. In such cases within the Netherlands, a General Fiscal Representative will provide a Dutch VAT number and handle the responsibilities related to VAT, ICL, and Intrastat reporting. Alternatively, the VAT can be deferred to the buyer in the country of delivery. To facilitate this, the sales invoice to the third party must include a statement indicating that ALS Customs Service is the fiscal representative of the buyer. In this situation, the customs clearance is based on the value of the last sale, which is the sales value to the buyer in the EU.

Discovering Fiscal Representation Options

  • Freight forwarders, who often work closely with customs service providers or have their own customs department, possess crucial knowledge and understanding of intra-Community delivery of goods.
  • In Fiscal Representation, freight forwarders do not play an active role but act as the principal to whom they send the bill.
  • If the delivery to the other EU country is not compliant, we, as the fiscal representative, remain liable for duties and taxes.
  • In the case of Delivery Duty Paid (DDP) deliveries, the seller of the goods assumes the role of the representative.
  • This option is particularly relevant for Small and Medium Enterprises (SMEs) based in third countries.
  • DDP incoterm imposes obligations on the seller to handle fiscal representation.
  • Unlike DDP, there is an alternative for representing the recipient of the goods.
  • Indirect representation is advantageous in this case, particularly in Germany.
  • For instance in the Netherlands, in a scenario like an ‘AB Shipment’, where direct representation is combined with fiscal representation, the VAT is deferred from the ALS VAT number to the VAT number of the buyer in the country of delivery.
  • However, it is not possible for ALS France to use Fiscal Representation services in this context, as representation must be done under common law.


Why choose ALS as your Fiscal Representation?

  • ALS provides broad coverage and comprehensive service alongside imports
  • ALS offers reliable services with minimal effort on your part
  • ALS Customs Services GmbH has specialised in fiscal representation since 1997, and they now have a dedicated department exclusively handling fiscal representation activities. Over 100 companies have already benefited from ALS Customs Services GmbH’s fiscal representation services alone.

Additional Information

Within the Netherlands, ALS sends a letter of receipt, otherwise known as a cover letter, before the 10th of every month for confirmation of VAT reporting. Upon request, ALS provides an Excel list with an overview of the declarations created, including values. Additionally, ALS requires two proofs of delivery e.g. signed CMR and invoice of domestic transport, after delivery.

How ALS facilitates your international trade

ALS is an innovative, neutral, and globally active customs broker. We operate as a unified entity, where every member of our team, from your dedicated contacts to our board of directors, is committed to meeting your specified needs.

We are here to guide you through all matters of international trade. Whether it’s speaking to one of our sales team, or requiring further guidance with our consultants, we offer everything to help facilitate your complete end to end customs.  

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At ALS, your customs path starts hereAt ALS, your customs path starts here
At ALS, your customs path starts hereAt ALS, your customs path starts here