VAT numbers, VIES checks and EORI in the Netherlands, Belgium and Luxembourg

Three numbers that decide whether your invoice is right

A company that sells goods across EU borders lives with three identifiers. The VAT identification number tells the tax authorities of every member state who you are for VAT. VIES, the EU's VAT Information Exchange System, lets anyone check whether a VAT number is active for cross-border trade. The EORI number identifies you in customs, whenever goods enter or leave the EU.

They look like administrative details, but each one carries money. A Dutch B.V. that sells EUR 80,000 of goods to a customer in Belgium without VAT relies on the customer's VAT number to justify the 0% rate. If that number was invalid at the time of the supply, the Dutch tax inspector can charge 21% VAT on the sale, EUR 16,800, plus interest and possibly a penalty, and the B.V. may never recover it from the customer. An importer without an EORI cannot clear goods through customs at all.

This note explains the formats in the Netherlands, Belgium and Luxembourg, how to read a VIES result, why the EU's 2020 Quick Fixes made the VAT number a substantive condition for the exemption, how recapitulative statements fit in, and who needs an EORI. A format checker at the end catches typing errors before you check a number in VIES.

What VAT numbers look like in the Benelux

Every EU VAT number starts with a two-letter prefix. Greece uses EL rather than GR, and Northern Ireland traders use XI for goods. After the prefix comes a national number with its own length and, in most countries, a check digit that catches typing errors.

The examples in this note are constructed to pass the check digits; they do not belong to real companies.

The Netherlands has two numbers. A Dutch business receives a btw-identificatienummer (btw-id) and an omzetbelastingnummer (ob-nummer). Both end in B and two digits, but only the btw-id carries the NL prefix and goes on invoices, the website and correspondence with customers. The ob-nummer is used only with the Belastingdienst. Since 2020 the two are different for sole traders (eenmanszaak and other zzp businesses): their ob-nummer contains their citizen service number (BSN), the btw-id does not. For a B.V. or N.V. the nine digits are based on the company's tax number (RSIN). A sole trader who puts the ob-nummer on an invoice publishes his BSN and gives the customer a number that VIES will reject.

Belgium uses the enterprise number. The Belgian VAT number is BE followed by the ten-digit enterprise number from the Crossroads Bank for Enterprises (KBO/BCE). For years all numbers started with 0; the 0-series ran out and the first number starting with 1 was issued on 19 September 2023. Software that still assumes a leading zero rejects valid new Belgian customers. Old nine-digit numbers are written with a leading 0.

Luxembourg is short. A Luxembourg VAT number is LU plus eight digits, issued by the Administration de l'enregistrement, des domaines et de la TVA (AED). It is distinct from the 11- or 13-digit national identification number used for direct tax and social security. Foreign companies registered for VAT in Luxembourg receive the same format.

Law and practice: Council Directive 2006/112/EC, Articles 214 and 215 (VAT identification and the country prefix); Article 226(3) and (4) (VAT numbers on invoices). Netherlands: Belastingdienst, "Alles over uw btw-identificatienummer en omzetbelastingnummer". Belgium: law of 16 January 2003 on the Crossroads Bank for Enterprises. Luxembourg: VAT Law of 12 February 1979.

How to check a VAT number and what a negative result means

VIES is a search engine, not a database. When you enter a number on the European Commission's VIES page, it queries the national database of the issuing country in real time and returns one of three answers: valid, invalid, or the member state service is unavailable. Some countries also return the registered name and address; others, such as Germany, do not.

1. Select the country and enter the numberWithout the prefix in the number field; remove spaces and dots.
2. Enter your own VAT number as requesterVIES then returns a consultation number, which proves that you checked and when.
3. Compare the name and addressWith the order, the contract and the delivery address; a valid number belonging to another company does not help you.
4. Save the resultA PDF or screenshot with the date and consultation number, filed with the invoice.
5. Repeat periodicallyFor regular customers at least once a quarter and whenever the customer's details change.

An invalid result has several possible causes. The number may be mistyped or invented. It may belong to a business that is registered for domestic VAT but not activated for intra-EU transactions, which happens in some member states when a company has not asked for it. It may have been deregistered, for example after a liquidation or a fraud investigation. And it may be brand new: a Dutch B.V. waiting for its btw-id or a Belgian company whose activation has not yet reached the system.

What you must not do is ignore it. For tax purposes the question is whether the customer was identified for VAT at the time of the supply, and the VIES result is your best evidence. If the national system was unavailable, try again later the same day. If the number stays invalid, ask the customer in writing for an explanation and a confirmation from its tax authority, and charge VAT until you have it. A credit note can correct the invoice once the number is confirmed.

Law and practice: Council Regulation (EU) No 904/2010 on administrative cooperation in VAT, Article 31 (confirmation of VAT numbers via VIES); European Commission VIES service (ec.europa.eu/taxation_customs/vies). The European Commission notes that VIES does not provide information on companies not registered for intra-EU transactions.

Intra-EU supplies: why the VAT number became a condition

An intra-EU supply of goods between businesses is exempt in the country of dispatch and taxed by the customer as an intra-EU acquisition in the country of arrival. Before 2020 the customer's VAT number was, in the case law of the Court of Justice, largely a formal requirement: if the supplier could prove that the customer was a taxable person and that the goods left the country, a missing or wrong number did not automatically cost the exemption (VSTR, C-587/10).

The Quick Fixes package changed that from 1 January 2020. Article 138 of the VAT Directive now lists the customer's VAT identification number as one of the substantive conditions for the exemption. The supplier may only apply the 0% rate if the customer is identified for VAT in a member state other than the one where the transport starts, and has given that number to the supplier. A second condition followed: the exemption does not apply if the supplier has not filed the recapitulative statement, or has filed it incorrectly, unless it can duly justify the failure to the tax authority.

The same Quick Fixes introduced simplified rules for call-off stock (Article 17a) and a single transport rule for chain transactions (Article 36a), both of which also depend on valid VAT numbers. In practice, a supplier that cannot show a valid VIES check for the customer at the time of supply should expect the tax inspector to charge local VAT at 21% in the Netherlands and Belgium or 17% in Luxembourg.

Law and practice: Council Directive (EU) 2018/1910 (Quick Fixes), amending Articles 17a, 36a, 138 and 262 of Directive 2006/112/EC, applicable since 1 January 2020; Council Implementing Regulation (EU) 2018/1912 inserting Article 45a into Implementing Regulation (EU) No 282/2011. Netherlands: Article 9(2)(b) VAT Act 1968 and Table II, item b.6; Belgium: Article 39bis VAT Code; Luxembourg: Article 43 VAT Law.

ICP, the Belgian listing and the Luxembourg état récapitulatif

Each exempt intra-EU supply of goods, and each service taxed under the reverse charge in the customer's country, must be reported in a recapitulative statement under the customer's VAT number. The tax authorities exchange these data through VIES and match them against the acquisitions declared by customers. A mismatch is the most common trigger for a cross-border VAT inquiry.

The EUR 50,000 threshold looks back: quarterly filing is allowed only if the threshold was not exceeded in the current quarter or any of the previous four. A growing exporter that crosses it mid-quarter must switch to monthly filing, in the Netherlands from the month in which it crossed. Correct an error in the next statement or by a separate correction; under Article 138(1a) an uncorrected error can cost the exemption itself.

Law and practice: Directive 2006/112/EC, Articles 262 to 271; Netherlands: Article 37a VAT Act 1968 and Belastingdienst guidance on the ICP period; Belgium: Royal Decree no. 50 on the intra-Community listing; Luxembourg: VAT Law of 12 February 1979 and guichet.lu, "Recapitulative statements for goods and services".

Who needs an EORI and how to get one in the Benelux

The Economic Operators Registration and Identification number is required for every person or company that lodges a customs declaration, an entry or exit summary declaration, or applies for a customs decision in the EU. That includes occasional importers and companies that use a freight forwarder or customs agent: the declaration is made in your name and needs your EORI. An operator has one EORI for the whole EU, issued by the member state where it is established.

A company established outside the EU registers in the member state where it first lodges a declaration or applies for a decision. A UK, US or Gulf seller that imports into Rotterdam therefore applies to Dutch Customs on the form for companies headquartered outside the EU; one that clears goods in Luxembourg applies to the ADA. A non-EU company that holds a Luxembourg VAT number uses it as its EORI. Without an EORI, customs will not accept the declaration, and goods wait in the warehouse at your cost.

The Authorised Economic Operator status (AEO) builds on the EORI. AEOC brings customs simplifications, such as entry in the declarant's records and lower guarantees; AEOS brings security and safety benefits, such as fewer physical checks. The status requires an EU establishment, a clean compliance record, sound records and, for AEOC, practical standards of competence. For regular importers it is worth considering once volumes justify the audit.

Law and practice: Regulation (EU) No 952/2013 (Union Customs Code), Articles 9 (registration) and 38 (AEO); Commission Delegated Regulation (EU) 2015/2446 and Implementing Regulation (EU) 2015/2447 on EORI registration. Netherlands: KVK, "Wat is een EORI-nummer?"; Luxembourg: guichet.lu, "Numéro EORI". Validate EORI numbers on the European Commission's EORI validation page.

Seven mistakes we see in Benelux VAT files

• The wrong Dutch number. A sole trader's ob-nummer on an invoice instead of the btw-id: VIES rejects it and the BSN is exposed.
• Leading-zero assumptions. Systems that reject Belgian numbers starting with 1, issued since September 2023.
• Checking once. A number valid at onboarding can be deregistered a year later; check regularly.
• Name mismatch. A valid VAT number of a group company other than the one that orders and pays.
• No evidence of the check. A VIES check without a consultation number or saved result is hard to prove.
• Listing not filed. Zero-rated sales left out of the ICP or listing: since 2020 this can cost the exemption.
• EORI confusion. Using a VAT number as EORI where it is not one, or a forwarder's EORI instead of your own.

VAT number format checker

The checker tests the structure and the check digits. A positive result means the number is plausibly correct, not that it is active: confirm that in VIES.

VAT numbers, VIES and EORI: frequent questions