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Tax: UK/US/UAE/KSA/EU · EU VAT & Cross-Border Rules · Card 009/010 hard

A small business established in Slovenia has annual EU-wide turnover of EUR 70,000, comfortably under the EUR 100,000 EU-wide ceiling, and wants to sell VAT-exempt to consumers in other member states without registering for VAT separately in each of them. Since 1 January 2025, under the SME scheme reform in Council Directive (EU) 2020/285, how does it access this cross-border exemption?

  1. It must separately apply for the exemption to the tax authority of every other member state where it has consumers, since granting the exemption remains a purely national decision for each destination country
  2. It notifies its own Slovenian tax authority of its intention to use the cross-border exemption, receives an identifier with an 'EX' suffix from that authority, and then files a single quarterly report to Slovenia disclosing the turnover generated in each other member state where it applies the exemption
  3. It automatically qualifies for the exemption in every member state the moment its EU-wide turnover is confirmed to be under EUR 100,000, with no notification or registration step required
  4. It can only use the exemption in member states where its Slovenian domestic turnover alone, rather than its EU-wide total, stays under that particular member state's own domestic exemption threshold
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