VAT on advice to a foreign client: when do you reverse-charge the VAT, and what goes in the EC Sales List?

If you work as a consultant or interim manager for a client abroad, you usually charge no Dutch VAT. Whether that is the case depends on two questions: is the client a business or a private person, and is the client in the EU or outside it.

With a business in another EU country, the work is not done with an invoice without VAT. You also report the service in your VAT return and in a separate list, the EC Sales List (opgaaf intracommunautaire prestaties, ICP).

In this article

1. Which VAT do you charge a foreign client as a consultant?
2. What do you put on the invoice to a business in another EU country?
3. How do you report the service in box 3b and the EC Sales List?
4. What do you do with a client outside the EU?
5. Do you charge VAT to a private person in another EU country?
6. Which exceptions should a consultant know?
7. Why does the tax authority look so closely at the EC Sales List?

Which VAT do you charge a foreign client as a consultant?

With a business client, usually no Dutch VAT. The law says that a service to a business is taxed where that business is established (art. 6(1) Turnover Tax Act 1968). For advice to a company in Germany that is Germany, for a company in the United States the United States.

With a private person it is the other way round. A service to someone who is not a business is taxed where you yourself are established, so in the Netherlands (art. 6(2)). There is one exception for advice: a private person outside the EU pays no Dutch VAT (art. 6i).

What do you put on the invoice to a business in another EU country?

An invoice without VAT stating VAT reverse-charged (btw verlegd). Reverse charging means that the client reports and pays the VAT itself in its own country. The Belastingdienst calls this an intra-community service (Belastingdienst, services to customers in other EU countries).

The invoice also shows your own VAT number and the client's VAT number (art. 35a(1)(c), (d) and (m) VAT Act). The VAT number is the VAT identification number you use in EU trade. You state the fee without VAT (Belastingdienst, reverse charge on the invoice).

Always check the VAT number before you invoice. You do that on the European Commission website (VIES). It shows whether the number is valid, and often the name and address too. If it does not match, ask the client for the correct details. Keep the result in your records (Belastingdienst, checking VAT numbers).

Note: an organisation that is not a business but does have a VAT number also counts as a business here, for example a public body or foundation with a VAT number (Belastingdienst). If the client has no valid VAT number, you treat it as a private person.

How do you report the service in box 3b and the EC Sales List?

You enter the amount in box 3b of the VAT return, supplies to and services in countries within the EU. In addition you file an EC Sales List: a list showing each client's VAT number and the amount. The total of the list must equal box 3b for the same period (Belastingdienst, EC Sales List).

• You report a service in the period in which you performed it. If you supplied nothing in a period, you do not need to file a list (Belastingdienst, EC Sales List).
• For services you may file the list monthly, quarterly or annually. Annually only with a permit. The limit of € 50,000 per quarter applies only to goods (Belastingdienst, period of the EC Sales List).
• If the service is exempt or taxed at 0% in the client's country, you do not put it on the list (Belastingdienst, EC Sales List).
• You correct a mistake in the next EC Sales List. More on the VAT return and the list is in filing a VAT return, including reverse charge and the EC Sales List.

If you use the small business scheme (KOR) or are considering it, note that turnover taxed in another country, such as advice to a business in the EU, does not count towards the turnover limit of € 20,000 (Belastingdienst, KOR conditions).

What do you do with a client outside the EU?

With a business outside the EU you do not report the service in your VAT return, if the service is taxed in that country (Belastingdienst, services to customers in non-EU countries). There is no EC Sales List, because that is only for clients in the EU. Do not show Dutch VAT on the invoice.

You may deduct the VAT on your own costs for that engagement, such as a laptop or software. The Belastingdienst writes that turnover made and taxed in a country outside the EU also counts as taxable turnover (Belastingdienst).

A separate rule applies to a private person outside the EU. Services of consultants, engineers, consultancy firms, lawyers, accountants and similar services are then taxed where the client lives (art. 6i(c) VAT Act). Granting licences and supplying staff also fall under this rule. So you charge no Dutch VAT.

Do you charge VAT to a private person in another EU country?

Yes, Dutch VAT. Advice to a private person falls under the main rule: taxed where you are established (art. 6(2)). Contact by e-mail or video call does not make it a digital service. The law says that exchanging messages over the internet does not in itself mean it is an electronic service (art. 6h(2) VAT Act).

It is different if you sell a digital service, such as an online course that runs largely automatically or a subscription to a tool. Then there is a threshold of € 10,000 a year for all sales to private persons in other EU countries together. Above it you charge the VAT of the client's country, and report it through the One Stop Shop (OSS) (Belastingdienst, services to private persons in the EU).

Which exceptions should a consultant know?

Two exceptions affect consultants most often. For these services the law points to a place other than the client's country (Belastingdienst, excepted services).

• Services relating to immovable property, such as a building or land, are taxed where that property is located. The law names, among others, experts, estate agents, architects and firms supervising construction (art. 6b VAT Act). If you advise on one specific building in Germany, the service may therefore be taxed in Germany, even for a Dutch client.
• Admission to an educational or scientific event, such as a conference or open training you organise, is taxed for a business client where the event takes place. That does not apply if the participant only attends online (art. 6d VAT Act).

If in doubt, use the Belastingdienst tool for supplying services to and from abroad. It is on the same page as the list of exceptions.

Why does the tax authority look so closely at the EC Sales List?

Because VAT on trade between EU countries is vulnerable to fraud. Keen and Smith describe in a review how the VAT credit and refund system creates opportunities for abuse, and that this became an urgent problem in the EU (Keen and Smith, 2006). The EC Sales List records a VAT number and an amount for each client. This creates a trail next to your return, and the total must equal box 3b.

Research shows that such data from the other party works. In two experiments among more than 400,000 firms in Chile, an announced extra check had less effect on transactions that left a trail with the other party. According to the researcher, this is because that trail already deters in advance (Pomeranz, 2015). For you this means: make sure the invoice, box 3b and the EC Sales List match exactly, because differences stand out.

Sources

• Turnover Tax Act 1968 (Wet op de omzetbelasting 1968), articles 6, 6b, 6d, 6h, 6i, 35a and 37a, version 1 January 2026. wetten.overheid.nl
• Belastingdienst, Calculating VAT on services to customers in other EU countries (in Dutch), accessed 31 October 2026. belastingdienst.nl
• Belastingdienst, Using the reverse charge scheme (invoice requirements, in Dutch), accessed 31 October 2026. belastingdienst.nl
• Belastingdienst, Checking a VAT identification number (in Dutch), accessed 31 October 2026. belastingdienst.nl
• Belastingdienst, EC Sales List (Opgaaf ICP, in Dutch), accessed 31 October 2026. belastingdienst.nl
• Belastingdienst, Period of the EC Sales List (in Dutch), accessed 31 October 2026. belastingdienst.nl
• Belastingdienst, VAT return when supplying services to customers outside the EU (in Dutch), accessed 31 October 2026. belastingdienst.nl
• Belastingdienst, I supply services to private persons in the EU (in Dutch), accessed 31 October 2026. belastingdienst.nl
• Belastingdienst, Calculating VAT on excepted services (in Dutch), accessed 31 October 2026. belastingdienst.nl
• Belastingdienst, KOR conditions (in Dutch), accessed 31 October 2026. belastingdienst.nl
• Keen, M. & Smith, S. (2006). VAT fraud and evasion: what do we know and what can be done? National Tax Journal, 59(4), 861-887. doi.org
• Pomeranz, D. (2015). No taxation without information: deterrence and self-enforcement in the value added tax. American Economic Review, 105(8), 2539-2569. doi.org