OSS and IOSS — VAT One-Stop Shop for E-Commerce in Spain

What Are OSS and IOSS?

The One-Stop Shop (OSS) and Import One-Stop Shop (IOSS) are EU VAT schemes introduced with the EU’s e-commerce VAT reform package on 1 July 2021 (Council Directive 2017/2455/EU). They replaced the previous mini-One-Stop-Shop (MOSS) system, which was limited to digital services, and extended the simplification to cover a much broader range of cross-border B2C transactions.

Before 2021, a company selling goods from France to consumers in Germany, Spain, Italy, and Poland needed to register for VAT in each of those countries (or stay below individual national distance-selling thresholds). OSS collapsed this into a single registration in one EU member state, with one quarterly return covering all EU B2C sales.

Spain implements OSS and IOSS through the AEAT’s dedicated Ventanilla Única (VU) portal, which processes registrations, declarations, and payments for all EU member states’ VAT on behalf of Spain-registered OSS participants.

How It Works in Spain

Three OSS Schemes

The reformed system has three components:

1. Union OSS For EU-established businesses. Covers:

• Intra-EU distance sales of goods (a German seller sending goods to Spanish consumers)
• B2C supplies of services where the place of supply is in a member state where the supplier is not established (e.g., a Spanish event company organising events in France)

Registration: in the member state where the supplier is established.

2. Non-Union OSS For non-EU-established businesses. Covers:

• B2C supplies of services to EU consumers (digital services, telecoms, broadcasting — and now all services supplied from outside the EU to EU consumers)

Registration: in any EU member state of the supplier’s choice. If the supplier has no EU establishment, it can choose Spain as its member state of identification and register with the AEAT.

3. Import One-Stop Shop (IOSS) For suppliers and marketplace facilitators involved in importing goods of €150 or less per consignment into the EU. Covers:

• B2C distance sales of goods imported from third countries with intrinsic value ≤ €150
• Electronic interface (marketplace) facilitation of such sales

Registration: EU-established suppliers register in their home state; non-EU suppliers must appoint an EU-based intermediary (tussenpersoon) and register through that intermediary in an EU member state.

The €10,000 Intra-EU Threshold

Below €10,000 of total annual cross-border B2C sales within the EU, a supplier can apply its home country VAT rate to all such sales (the domestic rule). This threshold applies in aggregate across all EU member states, not per country.

Once a supplier exceeds €10,000 in cross-border B2C sales in a calendar year, they must either:

• Apply destination-country VAT rates and register individually in each country concerned, or
• Register for OSS in their home member state and declare all intra-EU B2C sales through OSS

Most businesses above the threshold opt for OSS, which is far less burdensome than managing multiple national VAT registrations.

Registering for OSS in Spain

EU-established businesses registered in Spain register for Union OSS through the AEAT’s online portal (sede electronica). The AEAT then communicates the registration to all other member states’ tax authorities. Filing is quarterly, via the AEAT’s OSS portal, with payment made to the AEAT in euros. The AEAT distributes the VAT to each destination member state.

Non-EU businesses choosing Spain as their member state of identification register via the same portal, but using the Non-Union OSS form. Unlike direct Spanish VAT registration, OSS registration for non-EU businesses does not require a fiscal representative in Spain.

IOSS Registration and Intermediaries

Non-EU sellers using IOSS must appoint an EU-registered intermediary who takes joint liability for the IOSS VAT and files monthly IOSS returns on the seller’s behalf. The intermediary registers in a member state of their choice (typically where the intermediary itself is established). Monthly IOSS returns cover all EU B2C imports below €150.

Marketplaces (Amazon, eBay, Zalando, etc.) are “deemed suppliers” for IOSS purposes: if a non-EU seller uses a marketplace to sell into the EU, the marketplace collects and remits the VAT via its own IOSS registration, and the seller has no separate IOSS obligation for marketplace sales.

Key Regulations

• Council Directive 2017/2455/EU (amended by 2019/1995/EU): the EU legal basis for the reformed OSS/IOSS system
• Council Implementing Regulation (EU) 2021/2007: technical implementation rules
• Ley 37/1992 (Ley del IVA) as amended by Ley 7/2021: Spain’s domestic OSS transposition
• Real Decreto 424/2021: Spain’s implementing regulation for OSS/IOSS procedures
• AEAT Resolución on OSS/IOSS registration: operational guidance on the Ventanilla Única portal

Practical Implications for Foreign Investors

E-Commerce Businesses Selling Into Spain

For non-EU sellers sending goods to Spanish consumers:

• Value ≤ €150: IOSS is optimal — seller collects Spanish VAT (21% on most goods) at checkout, declares monthly via IOSS. Goods are cleared at customs without VAT collection.
• Value > €150: Standard import VAT rules apply at the border. OSS cannot be used for these imports.

For EU-established e-commerce businesses selling from a Spanish warehouse to consumers in France, Germany, and Italy: Union OSS with Spain as the member state of identification allows all the EU B2C sales to be declared in a single quarterly Spanish filing.

Marketplaces and Deemed Supplier Rules

Non-EU sellers using Amazon.es, Zalando, or other EU marketplace facilitators to sell to EU consumers should confirm whether the marketplace assumes IOSS/OSS responsibility as the “deemed supplier.” If so, the seller is relieved of IOSS obligations for marketplace sales — but may still have IOSS obligations for its own direct website sales.

Input VAT Recovery Limitation

OSS simplifies output VAT compliance but does not resolve input VAT recovery across member states. A Spanish-registered business using Union OSS still needs separate applications (under the EU 8th Directive refund procedure) to recover input VAT incurred in Germany, France, or other member states where it is not registered. This is a common oversight that results in unrecovered VAT costs for businesses expanding across the EU.

How BMC Can Help

We register companies for OSS and IOSS through Spain’s AEAT, prepare and file quarterly OSS and monthly IOSS returns, advise on the IOSS intermediary requirement for non-EU sellers, and manage the interaction between OSS/IOSS filings and Spanish domestic VAT obligations (Modelo 303) for businesses with both Spanish domestic and cross-border B2C sales. We also advise on the EU 8th and 13th Directive input VAT refund processes for businesses with input VAT trapped in other member states.