ViDA 2027: the VAT in the Digital Age changes taking effect on 1 January 2027

How does the deemed supplier regime change in 2027?

Article 14a of the VAT Directive sets out the "deemed supplier" rule: the legal fiction under which a platform or electronic interface facilitating certain sales becomes responsible for charging and declaring VAT, as if it had bought and sold the goods itself.

Until now, this rule applied when a platform facilitated the supply of goods by a non-EU established supplier to a non-taxable recipient (essentially, end consumers). From 2027, Article 14a(2) explicitly extends its scope: the platform will also be deemed to have received and supplied the goods when the recipient is a taxable person, or a non-taxable legal person, in addition to any other non-taxable person.

In practice, this means platforms facilitating sales made by suppliers not established in the Community will also become deemed suppliers in B2B transactions, not only in those directed at consumers.

How will the €10,000 threshold be calculated from 2027?

Article 59c of the VAT Directive sets the €10,000 annual threshold below which certain intra-Community distance sales of goods and certain TBE services (telecommunications, broadcasting and electronic services) may continue to be taxed in the supplier's Member State of establishment, rather than at destination.

Directive 2025/516 clarifies, in recital 36, that the calculation of this threshold must be based solely on distance sales of goods dispatched from the Member State in which the taxable person is established, excluding sales made from stock held in another Member State.

For businesses with inventory spread across several Member States, this is a relevant change: from 2027, sales made from stock held in another country will no longer count towards the threshold, which may allow many businesses to charge VAT on all their distance sales in their Member State of establishment, applying origin-based taxation.

What new supplies are brought into the Union One Stop Shop?

A new article, 369aa, is introduced, transitionally extending the scope of the Union One Stop Shop (OSS) to the supply of gas through a natural gas system situated in the Community (or a network connected to it), and to the supply of electricity, heating or cooling through heating or cooling networks.

A practical example of direct application is the supply of electricity to electric vehicles through charging points: from 2027, these transactions can be reported through the Union OSS scheme when made to non-taxable persons or entities whose intra-Community acquisitions are not subject to VAT, avoiding additional VAT registrations in each Member State where the service is supplied.

It is worth noting that this extension is transitional: Article 369aa itself sets its application until 30 June 2028, after which these transactions will need to fit into the general framework of the new own-goods transfer scheme that ViDA introduces in later phases.

How is the non-Union One Stop Shop scheme extended?

The special scheme for taxable persons not established in the Community supplying services to non-taxable persons (non-Union OSS, Article 359) is also amended. Until now, the wording of the article raised doubts as to whether this scheme covered all B2C supplies made within the Union, or only those directed at recipients established in the EU.

Recital 37 clarifies this point expressly: the scheme must cover all B2C supplies of services made within the Union by taxable persons not established there, not only those directed at recipients established in EU territory. The new Article 359 reflects this clarification.

Other minor adjustments

Directive 2025/516 also introduces minor technical amendments taking effect on the same date, including:

• Clarifications on the conditions for the refund of input VAT for taxable persons registered under the One Stop Shop special schemes (referencing Directives 86/560/EEC and 2008/9/EC).

• Adjustments to the rules on VAT chargeability under the cash accounting scheme (Article 66).

• An update to the "electronic address, including websites where applicable" data to be reported under the special schemes.

Member States are already adapting their national legislation

Although this is a directive, and therefore only directly applicable once transposed by each Member State, several countries have already begun adapting their domestic legislation to these new ViDA requirements. Belgium, the Netherlands and Poland are among those that have already published legislative developments in this regard, suggesting that other Member States will follow the same path in the coming months.