Netherlands: House of Representatives Adopts the ViDA Single VAT Registration Bill Without a Vote

KGT Country Update  |  21 September 2026  |  VAT, e-invoicing and SAF-T monitor

On 17 September 2026, the Dutch House of Representatives adopted bill 36920, the Act implementing the VAT in the Digital Age Directive single VAT registration, as a hamerstuk, meaning it was passed without debate and without a vote.

The bill transposes the single VAT registration component of Council Directive (EU) 2025/516 into the Turnover Tax Act 1968. It enters into force on 1 January 2027, introduces a new mandatory reverse charge and a transfer of own goods scheme from 1 July 2028, and repeals the call-off stock regime from 1 July 2029. The bill now goes to the Senate.

Background

Council Directive (EU) 2025/516 of 11 March 2025 amends Directive 2006/112/EC in respect of VAT rules for the digital age. It has three pillars: digital reporting requirements, the platform economy, and single VAT registration, and its transposition deadlines are staggered article by article rather than falling on a single date. The single VAT registration package is the near-term one: the earliest measures apply from 1 January 2027.

The Netherlands has taken these components in two separate instruments. KGT reported on 14 September 2026 that the Cabinet has committed to a domestic B2B e-invoicing mandate from July 2030 and digital reporting from July 2031, aligned with the Directive's own application date rather than ahead of it. Bill 36920 is a different instrument and should not be confused with it: it concerns the one-stop-shop schemes and the treatment of own goods movements, and contains no e-invoicing or reporting obligation.

The bill was submitted to the House on 26 March 2026 with the Council of State's advice. The committee report stage closed on 13 May 2026; the note in response to the report and a note of amendment were filed on 10 July 2026; the Finance Committee listed the bill for plenary treatment as a hamerstuk on 9 September 2026; and it was adopted on 17 September 2026.

The Legislative Change

Article I amends the Turnover Tax Act 1968 with effect from 1 January 2027.

The changes clarify and widen the existing one-stop-shop schemes: the deemed supplier rule in Article 3c is extended so that the facilitated supply may be made to a taxable person, or to a non-taxable legal person whose intra-Community acquisitions are not subject to tax, as well as to any other non-taxable person; the identification and reporting rules for the non-Union scheme, the Union scheme and the import scheme are aligned; and the input VAT position under each scheme is restated so that deduction is not taken through the scheme but by way of refund under the Eighth and Thirteenth Directives.

Article I also inserts into Article 3b(2)(a) the words prior to or at the latest on 30 June 2028, which is the mechanism by which no new call-off stock arrangement may begin after that date.

Article II is a transitional measure. From 1 January 2027 to 30 June 2028, supplies of gas through a natural gas system situated in the Union or a network connected to it, of electricity, and of heat or cold through heating or cooling networks are treated as intra-Community distance sales for the purposes of the Union scheme where they are made by a supplier not established in the Member State of taxation. That brings these supplies into the one-stop-shop eighteen months before the wider 2028 package.

Article III contains the amendments taking effect on 1 July 2028, and it is the operative part of the bill for most multinationals. Two changes matter.

The first is a new Article 12(4), a mandatory reverse charge. Where a supplier is not resident or established in the Netherlands and has no fixed establishment here from which the supply is made, has not been allocated a Dutch VAT identification number, and the recipient has been allocated a Dutch VAT identification number, the tax is levied from the recipient. The note of amendment of 10 July 2026 inserted the words "and by way of derogation from the third paragraph", so that where both the existing Article 12(3) reverse charge and the new Article 12(4) would apply to the same supply, the new provision takes precedence. That resolves in the statute itself the question of which reverse charge governs.

The second is a new Paragraph 5 of Chapter V, Section 7 the special scheme for the transfer of own goods, Articles 28to to 28tx. A trader making a transfer of its own goods to another Member State may use the scheme, and if it does, the scheme applies to all such transfers. The scheme covers transfers within the meaning of Article 17(1) of the VAT Directive, excluding transfers of goods in respect of which there is no full right of deduction in the destination Member State. Identification follows the seat of business, or a fixed establishment, or the Member State where dispatch begins, with a two-calendar-year lock on any election.

A VAT notification is filed electronically for each calendar month, whether or not any transfer was made, before the end of the following calendar month, in euro, converted at the European Central Bank rate for the last day of the month.

The corresponding intra-Community acquisition is exempt under the new Article 28tv. Input VAT relating to scheme activities is not deducted through the scheme but refunded under the Eighth and Thirteenth Directives. Records must be kept for ten years after the end of the year of the transaction and made available electronically to the Member States of departure, destination and identification on request.

A new Article 34aa imposes a notification duty that is easy to overlook. Where a trader transfers goods to another Member State on behalf of another trader, and the transfer is not made at that other trader's express request, it must inform that other trader that the goods are being or will be transferred, no later than the time of dispatch or transport. This is a logistics obligation as much as a tax one.

Article IV repeals Article 3b with effect from 1 July 2029, together with the associated recapitulative statement provisions in Articles 34(2)(c) and (d) and 37a(1)(d). That ends the call-off stock simplification.

Article V sets entry into force at 1 January 2027, with retroactive effect to that date if the Bulletin of Acts and Decrees is published later.

Scope

The bill is about registration and reporting mechanics, not about invoicing. It affects any business that is, or could be, VAT-registered in the Netherlands without being established there; any business moving its own stock into or out of the Netherlands; and any business currently relying on the call-off stock simplification for Dutch flows.

It does not change Dutch invoicing requirements, does not introduce structured e-invoicing, and does not introduce transaction reporting. Those sit in the separate instrument covering the 2030 and 2031 dates.

Timeline

• 17 September 2026 adopted by the House of Representatives as a hamerstuk, without a vote.
• Pending consideration by the Senate. The bill is not law until it has passed the Senate and been published in the Bulletin of Acts and Decrees.
• 1 January 2027 entry into force; Article I amendments and the Article II transitional treatment of gas, electricity, heat and cold take effect.
• 30 June 2028 the last date on which a new call-off stock arrangement may begin.
• 1 July 2028 the new mandatory reverse charge in Article 12(4) and the transfer of own goods scheme in Articles 28to to 28tx take effect; the Article 34aa notification duty begins.
• 1 July 2029 Article 3b, the call-off stock regime, is repealed.

Businesses Affected

Non-established suppliers with a Dutch VAT registration are the most directly affected. From 1 July 2028, a supplier that is not established in the Netherlands and holds no Dutch VAT identification number will not charge Dutch VAT to a customer that holds one; the customer accounts for it. For groups that currently maintain a Dutch registration solely to charge local VAT on such supplies, the registration may cease to be necessary, which is the point of the reform, but deregistration is a decision with consequences for input VAT recovery and should not be taken on the strength of the reverse charge alone.

Groups moving their own stock cross-border are the second population. The transfer of own goods scheme replaces the pattern of registering in each Member State where stock is held. It is elective, but it is all-or-nothing: electing in means every qualifying transfer goes through the scheme.

Businesses using call-off stock must plan for its withdrawal. No new arrangement may begin after 30 June 2028 and the regime disappears on 1 July 2029, so contracts and logistics arrangements written on the assumption of call-off stock need a defined exit.

Logistics providers and group entities that move goods for other group entities acquire the Article 34aa notification duty. Where a central logistics company moves stock for operating companies without an express request in each case, it must notify them at or before dispatch.

Required Actions

• Map the Dutch registration estate now. For each non-established entity holding a Dutch VAT number, establish why it holds it, and test whether the 1 July 2028 reverse charge removes the reason. This is an analysis to start in 2026 because deregistration timing interacts with input VAT recovery and with statistical and customs obligations.
• Identify every own-goods movement into and out of the Netherlands, and decide whether the transfer scheme will be elected. The decision is a group decision, not a country decision, because the scheme applies to all qualifying transfers once elected.
• Build the monthly notification. The transfer scheme requires a monthly filing regardless of activity, with amounts per Member State of destination and, where dispatch is from a Member State other than the Member State of identification, per Member State of departure. Nil returns are required. This is a new recurring filing and needs an owner and a data source.
• Fix the reverse charge determination logic before 1 July 2028. The condition set in Article 12(4) is precise supplier not established and holding no Dutch VAT identification number, recipient holding one — and the note of amendment makes clear that where both reverse charges could apply, the new one wins. Tax determination in the ERP has to reflect that priority, and it has to test the supplier's registration status, not merely its establishment.
• Close out call-off stock. Inventory the arrangements, agree an end date for each, and confirm that the receiving entity has a registration or a transfer scheme election in place to absorb the flow from 1 July 2029.
• Implement the Article 34aa notification where goods are moved for another group company. This is a process and documentation change in the logistics function.

Practical Implications

The most consequential feature of this bill is the one least likely to be picked up by a compliance calendar: a mandatory reverse charge changes the output of the tax determination engine, and it changes it for a population defined by a fact the seller does not always know: whether it holds a VAT identification number in the customer's country. Systems built to determine VAT from establishment and from the customer's VAT number will need an additional input. Groups that have automated Dutch determination should treat 1 July 2028 as a system date, not a policy date.

The transfer of own goods scheme is genuinely simplifying, but it substitutes one obligation for another. A group that deregisters in several Member States in reliance on it replaces several periodic VAT returns with one monthly notification and a ten-year record-keeping obligation covering movements rather than supplies. The data required value excluding VAT of transfers per Member State of departure and destination, per month is not a data set most ERP systems produce today, because stock transfers are not normally valued for VAT purposes at the point of movement.

The repeal of call-off stock has a long tail. Arrangements beginning before 30 June 2028 continue until 30 June 2029, so 2028 and 2029 will be run under two regimes simultaneously. That is a reconciliation burden, and it is a reason to end existing arrangements deliberately rather than let them run to the statutory cut-off.

Finally, the fact that the bill passed as a hamerstuk is itself informative. A bill adopted without debate or vote is one on which there is no political controversy, which means the timetable is unlikely to slip. Businesses should plan on the dates in the bill.

Expected Next Steps

The bill goes to the Senate. A hamerstuk in the House normally proceeds quickly in the Senate, and the government needs the Act in force by 1 January 2027; the retroactivity clause in Article V exists precisely to protect that date if publication slips.

Article 6k as amended permits further rules by ministerial regulation on the administration evidencing an election, so a ministerial regulation is to be expected before 1 January 2027. The mechanics of the identification register for the transfer scheme, and the electronic filing channel for the monthly notification, will also need to be published before 1 July 2028.

KGT will report the Senate stage, publication in the Bulletin of Acts and Decrees, and the implementing regulations.

How Can KGT Support You?

KGT delivers SAP-integrated tax determination, electronic invoicing and statutory reporting. For this reform the work is mostly in determination and in data: configuring SAP so that the new Dutch reverse charge is applied on the correct condition set from 1 July 2028 and takes priority over the existing reverse charge, and building the movement data set that the transfer of own goods scheme requires from stock transfer documents rather than from billing documents.

Our SAP add-on for tax determination extends standard SAP logic where the condition technique cannot express a rule of this shape, and we support the registration analysis that has to precede any deregistration decision. For clients running SAP Document and Reporting Compliance we support scoping, configuration and the reconciliation controls between the statutory filings and the underlying SAP data.

This country update is provided for general information only and does not constitute tax, legal or professional advice.