We have our own IOSS number - Can we use it, instead of Amazon's Number

This is a tricky minefield but I can tell you that we are:

• happily registered only for IOSS (via Italy)
• not registered for VAT in any EU country
• using all EU Amazons except Poland and including Germany
• Selling products B2C and B2B on Amazons and selling products above and below the IOSS threshold
  So you definitely don’t need to be registered for VAT in Germany. I don’t know why you think you’ve been chucked off Amazon Germany for that reason? But there are other issues around this topic and I will try to highlight a few we have come across.

First thing is that for small companies like us using couriers to fulfill, it usually isn’t us who ends up as the importer of record. It’s the courier who clear things on your behalf as an agent. That’s how they get round the requirement to register for VAT in the destination country, I believe (but someone correct me if I have this wrong). If you send something, you can send it DDP in which case you are the importer of record then you ARE required to register for VAT in the destination country (I think). Or you can send DAP and then the customer is the importer of record but this is against Amazon T&Cs. So I think what mostly happens is that technically we are not sending DDP, we are sending DTP which means an agent clears something on your behalf and the agent is registered for VAT in that country.

It also seems to be in many cases that it’s the country of importation that counts, not the country of destination. For instance, a shipment sent by road to Austria from the UK will not hit the EU border in Austria and so may end up getting cleared in somewhere like the Netherlands. And so for a non IOSS shipment, you may pay a Netherlands rate of import VAT, not an Austrian rate and be subject to the vagaries of Netherlands customs, not the Austrian.

• It is possible to register for VAT in any EU country and if you do that, you can recover any import tax paid (this obviously only applies to non IOSS shipments).
• One of our couriers P2P will no longer take any non-IOSS deliveries to the EU unless we register for VAT in the Netherlands which happens to be where they clear all their EU bound shipments. We aren’t registered so we now can only use them for IOSS shipments.
• Another one of our couriers, DPD are currently have trouble with Germany bound non-IOSS shipments. Although we’re sending them DTP meaning that as far as we are concerned, the customer should not be contacted, they still are contacting the customer because German customs apparently require the customer to give DPD power of attourney to clear the shipment. Bizarre.
• Spanish customs are being particularly awkward and are insisting that commercial invoice info includes either a personal tax ID or an EORI number for every shipment - we’ve had several returned because this wasn’t supplied even though the EU certainly don’t require it.

We have also seen the French being stupidly pedantic about customs info and returning shipments for reasons that do not follow basic EU law. France and Spain have a long reputation for government organisations that are extremely bureaucratic and officious so perhaps no surprise but in general I think it’s more likely that a number of countries are deliberately putting impediments in place as a way to put the boot in for Brexit.