Business customers: zero rating and reverse charge
A Maltese company that supplies services to a VAT-registered business in another member state usually does not charge Maltese VAT. The customer accounts for the VAT in its own country through the reverse charge, and the invoice must make that clear, with the customer's VAT number and a reference to the reverse charge.
For goods sent to a business in another member state, the supply is typically zero-rated when the customer has a valid VAT number and the goods really move. The Maltese supplier reports the sale in its VAT return and the related recapitulative statement, and the customer reports the acquisition.
Both treatments rely on the customer being a business. If the customer is a private individual in disguise, for example a sole trader who has not registered, the rules change and VAT may be due.
Document the status of the customer at the time of the sale. A screenshot of the VIES result, the company registration extract and the signed order form together answer almost any later query about why you did not charge Maltese VAT.
Consumer sales and the One Stop Shop
Selling to consumers in other member states used to mean registering for VAT in each of them. Since 1 July 2021 the OSS lets a business report and pay the VAT due in several member states through one quarterly return filed in its own state, which for a Maltese business is with the CfR.
An EU-wide threshold of €10,000 for cross-border B2C sales of goods and certain services allows a business below it to keep charging its home VAT. Above it, VAT is due in the country of the consumer at that country's rate, and the OSS return reports each country separately.
Joining the OSS is voluntary but it is the practical option for anyone with sales in several states. Ask your adviser how the CfR handles registration and what records to hold, since the return is based on the invoices and the destination country of each sale.
Consider a Maltese online course provider with students in France, Italy and Germany. Each sale is taxed at the rate of the student's country, the invoice shows that rate, and the quarterly OSS return lists the three countries separately with the net amount and VAT due for each.
Imports of low-value consignments and the IOSS
Goods bought by consumers in the EU from non-EU sellers in consignments up to €150 can be handled through the Import One Stop Shop. The seller charges VAT at the destination rate at the time of sale and reports it monthly, and the goods clear customs without further VAT at the border.
For a Maltese business that fulfils such orders, the IOSS affects how you price, what the customer pays and who is responsible for the VAT. If you do not use it, the customer or the carrier pays VAT at import, often with fees that annoy buyers.
Ask your logistics partner which scheme they support. The data on the invoice and in the shipping declaration must match.
Returns, damaged goods and cancelled orders deserve a rule. Decide in advance who covers the VAT on returned items, how the credit is issued and what happens when a customer in another country refuses delivery.
Digital services to consumers
Services supplied electronically, such as software downloads, streaming or online courses, to consumers in other member states are taxed in the consumer's country. The OSS is the tool to report them, and the supplier must determine the customer's location using the evidence the rules set out, such as billing address and IP location.
The place of the customer determines both the rate and the invoice content. A subscriber in Finland and a subscriber in Spain pay different VAT on the same product, and your prices must handle that, whether by adjusting the net price or by letting the gross price differ by country.
Keep the evidence for each sale. If an authority challenges the location, the file needs two pieces of non-contradictory data.
Marketplaces can change the picture, since a platform may be treated as the supplier for some consumer sales and collect the VAT itself. Read the platform contract and ask the adviser which of your sales sit outside your own return.
Records, invoices and deadlines
The OSS return is quarterly, and payment is due on the same schedule, so a missed deadline can bring penalties and interest in the same way as an ordinary VAT return. Calendar the due date and give your accountant sales data by country well before it.
Invoices to consumers should state the VAT rate of the destination country and the amount. For business customers, the invoice carries the VAT number and the reverse charge wording. Keep copies for the period set by the law.
Credit notes and refunds in an OSS quarter are corrected in the relevant OSS return and must refer to the original transactions. A refund that is not mapped to the right country and period is an easy way to misstate VAT.
What the ecosystem does and does not do
4invoices.net lets you set the VAT rate and the wording on each PDF invoice and keeps copies in an archive that can be exported by period. 4softerp.net holds multi-company accounting records for the books behind the return.
4b2b does not prepare or file OSS or IOSS returns, does not know the VAT rates of other member states and does not verify customer locations. You or your adviser pick the right rate and prepare the return with the CfR.
A good setup is a monthly export of issued invoices, a sheet that groups them by destination country, and a quarterly review with the accountant before the OSS due date.
If you operate in a country where you also hold stock, you may need a local VAT registration in addition to OSS, because the scheme does not cover every transaction type. Review stock locations once a year.