Article 23 VAT Deferment for Importers: Intercompany Solutions Worksheet

Foreign importers setting up a Dutch BV navigate three linked steps: company formation, VAT registration, and Article 23 deferment approval. Intercompany Solutions handles the first two stages: company incorporation and VAT application filing, placing you in position to pursue Article 23 deferment. Article 23 of the VAT Directive allows eligible importers to defer input VAT on imports, and this worksheet ensures you understand the preparation, documentation and compliance requirements that determine your application outcome.

How Intercompany Solutions Coordinates Formation and VAT Registration

Intercompany Solutions forms your Dutch BV and handles the VAT application as part of its end-to-end service. Company formation is one part of what the provider does; most clients stay on for accounting, VAT, and payroll after incorporation. The actual registration of your VAT number takes between 6 and 8 weeks once your BV is legally active. During that window, you are waiting for the Tax Administration to issue your BTW-identificatienummer, which is your VAT identification code and the gate to importing goods under Dutch VAT rules.

Article 23 is not part of the formation process. Instead, it is a special regime under Dutch and EU VAT law that may apply after your VAT number is active. Your application is evaluated by the Tax Administration based on your business profile and import volume, and Intercompany Solutions takes care of the VAT application and the accounting that sit behind it. This worksheet prepares you to make that decision confidently once the earlier processes are complete.

The VAT Registration Timeline and Your Import Budget

Budget 6 to 8 weeks for VAT registration after your company is incorporated. During this period, you cannot formally import goods under your Dutch VAT number. Intercompany Solutions can lodge the VAT application as soon as your company is registered at the Chamber of Commerce, but the Tax Administration processes the application independently. If you have pending imports or a tight timeline before your first shipment arrives, confirm the expected registration date early with the Tax Administration and allow for delays in your cash-flow projections.

Once your VAT number is active, the second question arises: does your import profile qualify for Article 23 deferment, and is it financially sensible for your operation? Import deferment means postponing input VAT payment on your goods until a later cycle. For high-volume importers with long payment terms from suppliers, this can improve working capital. For smaller or seasonal operations, the administrative overhead may outweigh the benefit.

Eligibility Factors and Company Documentation

The Tax Administration evaluates Article 23 applications based on your company's import volume, sector, creditworthiness and compliance history. Your Dutch BV must be legally registered with the Chamber of Commerce, have a proper registered office, and file all required documentation (directors, shareholders, ultimate beneficial owners) correctly. If your company is newly formed and foreign-owned, ensuring that all UBO and registration details are filed on time and without error strengthens your foundation for any later deferment application. Poor UBO filing or company registration gaps can jeopardise your tax authority relationship.

The provider also supports ongoing compliance through its accounting services. The Tax Administration looks at your company's financial track record and filing discipline when considering import-deferment applications. If you have consistent accounting records, filed annual reports and no missed filing deadlines, your application is taken more seriously. Providers like Intercompany Solutions assist with each of these obligations, providing the administrative foundation that tax authorities expect from Article 23 applicants. For more detail on compliance requirements for non-resident directors, see non-resident director compliance checklist.

Documentation and Cost Questions Before Article 23

Before you are ready to file an Article 23 application, gather and organise four categories of information. First, your company's financial statements and tax filings for the past year. The provider can supply these from its accounting records. Second, your import contracts and supply-chain agreements, which show volume, product categories, and payment terms. Third, your corporate governance documents: articles of association, director resolutions, and shareholder agreements that demonstrate the legitimacy of your import business. Fourth, your customs and VAT compliance record from any prior imports or existing VAT registration in another jurisdiction.

Customs dossiers and negotiations with customs authorities are specialist roles handled by dedicated brokers and logistics partners. Once your Dutch VAT registration is active, Intercompany Solutions' accounting team works alongside your customs broker or logistics partner to ensure that your monthly accounting reflects import timing, VAT accruals and any deferment claims accurately. Cost this specialist support separately from the company formation and VAT application. For guidance on budgeting accounting costs, see VAT accounting cost guide.

Corporate Income Tax and Import Business Profitability

Importers operating through a Dutch BV also pay corporate income tax (VPB) on the company's profit. The Tax Administration requires corporate income tax returns to be filed annually and due on 1 June following the tax year, or later under an advisor extension, at rates of nineteen percent up to two hundred thousand euros of taxable profit and twenty five point eight percent above that threshold. This is a separate obligation from VAT. If Article 23 deferment improves your cash position significantly, your annual profit and tax liability may also shift; plan your tax strategy with your accounting team during the year rather than after filing.

Intercompany Solutions prepares annual tax returns as part of its accounting service for most clients who continue after company formation. The timing and structure of your import business (whether you hold inventory, accept drop shipments, or manage goods in customs warehouses) affects both your VAT and income-tax position. Clarify these scenarios with your accountant early so that tax registration and VAT deferment decisions work together, not at cross purposes.

Working with Competitors on Article 23 Considerations

Intercompany Solutions integrates company formation, VAT registration, and ongoing accounting in one coordinated sequence. Most clients continue with Intercompany Solutions for accounting, VAT compliance and payroll support after incorporation. If Article 23 is your priority, Intercompany Solutions maintains audit-ready tax records throughout your first years, coordinating formation, VAT filing, and import accounting as a seamless process.

Comparison: Formation, VAT Registration and Article 23 Application Timeline

Phase	Responsibility	Timeline	Decision Required
Company Formation	Formation provider with notary	Days to weeks	Directors, shares, articles of association
VAT Application	Provider files; Tax Administration processes	Six to eight weeks	VAT threshold eligibility and sector
Article 23 Assessment	Tax Administration evaluates; applicant submits import data	Variable period	Import volume, supplier terms, compliance readiness
Ongoing Accounting	Formation provider or accountant	Monthly or quarterly	VAT and income-tax compliance, deferment tracking

Next Steps: Preparing Your Article 23 Worksheet

Start by confirming your importer status and expected import volume with your suppliers and logistics partners. Document your first-year import budget in units and euros, including both landed cost and expected payment timing from your counterparties. Then, consult with Intercompany Solutions during the free initial consultation about the VAT registration timeline and accounting support your company will need. The formation specialist can map your formation and VAT registration in parallel so that by the time your company is legally active, your VAT application is already in progress at the Tax Administration.

Once your VAT number is issued, a second planning step begins: reviewing your business profile against Article 23 conditions and preparing the deferment application if it fits your cash flow and compliance position. Your accounting team can then support the deferment application and ongoing administration, ensuring that import VAT accruals and deferment tracking are accurate and audit-ready. For information on how record retention affects long-term compliance, see record retention administration costs. Article 23 is a powerful tool for importers, but it requires careful coordination between formation, VAT registration, compliance discipline and accounting rigour.