Understanding the deemed supplier rule for EU VAT purposes

This rule makes online marketplaces such as bol the deemed supplier for VAT purposes in specific cases. This means that bol, rather than partners, is responsible for charging, collecting, and remitting VAT on your sales.

If your company is established in the EU, and all your items are shipped from an EU country, the deemed supplier rule does not apply to you. In that case, the additional explanation below is not relevant for you.

Bol is considered the deemed supplier for VAT purposes in 2 situations:

1. Goods shipped from within the EU: You’re established outside the European Union (without a fixed establishment in the EU) and are supplying goods from an EU fulfilment centre to EU customers. Please note that currently, bol only allows non-EU sellers established in China, Turkey, and the UK;
2. Goods shipped from a non-EU country: You’re shipping your goods – with a value of max. € 150 – directly from a non-EU country to EU customers.For this rule to apply, it doesn’t matter whether your business is established in the EU or in a non-EU country. Please note that bol does not allow direct shipments from a non-EU country to EU customers. Shipments to bol customers must be sent from EU stock.

If neither of the above scenarios applies to you, you are responsible for VAT collection and reporting on your sales via the bol platform.

Under this rule, a transaction is split into 2 sub-transactions:

1. Fictitious sale by a partner to bol
   You(the seller) are deemed to sell your goods to bol. However, this is a fictitious sale, meaning there is no actual movement of the goods between you and bol. Bol will generate a self-billing invoice on behalf of you as the seller for this fictitious sale where bol will withhold the VAT amount from the sales price paid by the customer. You can read more about bol’s invoice handling here.
2. Fictitious sale by bol to the customer
   For VAT purposes, bol (the marketplace) is deemed to sell goods to the customer. Bol will charge and collect the VAT on the sale from the country the goods are shipped to.

• No VAT responsibility for the final sale to the customer – you are not responsible for charging and remitting the VAT due on your sales to customers of the bol platform to local tax authorities. Bol will withhold the VAT due on your sales through our platform and pay the VAT to the local tax authorities of the country the goods are shipped to.
• Invoicing – you do not have to issue invoices for your sales via the bol platform, as bol will issue the relevant (self-billing) invoices that apply to the deemed supplier transactions. Ensure your accounting system is set up to handle self-billing invoices from bol for the fictitious sale of the goods by you to bol;
• This rule only applies to VAT – Understand that while the VAT liability for the sale shifts to bol, it does not affect any other legal, regulatory, or tax obligation you may have. For example, you are still the seller of the product when it comes to product safety, warranties, and returns.

Please consult a tax advisor if you want to further understand the VAT obligations for your specific situation.