Importing goods into the Netherlands can strain your cash flow, if you have to pay value-added tax (VAT) up front—in 2023, the Netherlands collected about €75.6 billion in VAT. The Article 23 license (artikel 23 vergunning in Dutch) offers businesses another option by turning the tax from an immediate expense to a line item on your return.

Understanding how to secure and use this deferment license can free up capital, simplify VAT reporting, and speed up customs clearance for businesses that regularly bring products into Europe. This guide will explain the rules and eligibility criteria for Article 23, as well as practical steps to applying.

What’s in this article?

• What is Article 23 VAT deferment in the Netherlands?
  
• How does Article 23 improve business cash flow?
  
• Who is eligible for an Article 23 license?
  
• How do you apply for VAT deferment under Article 23?
  
• How do businesses use the Article 23 license in practice?
  
• Why is the Dutch Article 23 approach unique in Europe?
  
• How Stripe Atlas can help
  

What is Article 23 VAT deferment in the Netherlands?

When goods land in a Dutch port, the default rule is that 21% VAT is due immediately on the customs value. Article 23 changes this by allowing a business to record the import VAT on its next Dutch VAT return rather than pay VAT at the border. In that return, the importer deducts the same amount as input tax so the net effect on cash is zero. Effectively, the permit turns a payment into a bookkeeping entry and lets companies clear goods without waiting for customs to process a refund.

Under Article 23, you still declare the imported goods in box 4a of the Dutch VAT return. The VAT base must be the customs value shown on the customs payment notice (uitnodiging tot betaling or UTB in Dutch) rather than the one on the purchase invoice. Because the UTB reflects the proper customs valuation, using it ensures your return matches what customs recorded. Article 23 doesn’t waive customs duties or excise taxes either so you still settle those amounts when the goods arrive.

How does Article 23 improve business cash flow?

Importing goods typically means paying VAT to customs and waiting weeks or months to reclaim it through your VAT return. That outlay can be a substantial drain, especially if your margins are tight or you’re scaling fast. Article 23 changes the rhythm. When you import, you record the VAT on your next return instead of paying it up front. You declare the value of the goods and calculate the VAT due, and you deduct that amount as input tax in the same return. Your cash consequently stays in the business.

Customs can also clear your goods more quickly because there’s no VAT payment to process, which helps avoid delays and reduce warehousing costs. And VAT on imports becomes a regular line item in your return so you know exactly when it will appear and disappear from your books. This makes it easier to align incoming stock with sales cycles and plan for peaks and troughs.

Who is eligible for an Article 23 license?

Article 23 is designed for businesses that have a presence in the Netherlands and import goods on a recurring basis. Here are the requirements set by the Dutch tax authority.

Establishment in the Netherlands

You need to be established or resident in the country. This can mean a registered company, branch, warehouse, or other fixed establishment. The tax office wants proof that you’re operating from Dutch soil.

Foreign entrepreneurs face additional steps. They cannot apply directly for Article 23; instead, they need to appoint a Dutch tax representative.

There are two types of representation:

• Limited representation: This means the representative imports goods using their own VAT number and handles only the specific transactions you assign.

• General representation: This allows you to obtain your own Dutch VAT number while the representative manages filings and compliance on your behalf, giving you more flexibility.

Regular imports from outside the EU

The permit isn’t meant for one‑off shipments. You’ll be asked to show evidence of regular importing activity, such as order confirmations, purchase invoices, and customs declarations.

Separate administration

Your records must clearly identify the VAT owed on each import. That means maintaining a distinct ledger or module in your accounting system so customs and tax officials can easily verify import values.

Financial guarantee

A financial guarantee is mandatory. There’s a minimum guarantee of €5,000, but it scales with your import volumes and risk profile. The guarantee is often provided by the tax representative if you’re a nonresident business.

How do you apply for VAT deferment under Article 23?

You should view the Article 23 application process as part of a broader compliance strategy. Accurate documentation, timely filings, and a proactive relationship with the tax authority can make the process smoother.

Here are the steps to apply for deferment and why each one matters.

Register for VAT in the Netherlands

You need a Dutch VAT number before you can apply. If you’re a nonresident, your tax representative will get you a VAT registration as part of their mandate.

Assemble your supporting documents

The tax office needs to see proof that you import regularly. Pull together recent purchase orders, invoices, and customs declarations. Attach copies to your application. Including these documents up front reduces the risk of back‑and‑forth requests later.

Complete the application form

The form asks for your company’s details, VAT number, business description, and how often you import. Be thorough: list your VAT number on every attached document and describe your goods and their countries of origin. This context helps the tax office assess your risk profile and determine the size of the financial guarantee.

Arrange a financial guarantee

A bank guarantee or financial deposit is required. It protects the treasury in case import VAT isn’t properly accounted for. If you’re using a tax representative, they might provide the guarantee on your behalf.

Submit your application to the tax office

Send the completed form and attachments to the Dutch tax authority by post or via the online tax portal. Apply with plenty of lead time, because processing can take about eight weeks and you don’t want your goods stuck at customs while you wait.

Wait for the decision

During the review period, the tax authority will verify your eligibility, assess your documentation, and confirm that your guarantee is sufficient. You’ll receive a written decision. If your application is approved, you can start using Article 23 immediately on future imports.

The tax representative will oversee most of these tasks for nonresident companies. They’ll prepare the application, arrange the guarantee, submit the paperwork, and handle any questions from the tax office. The representative also manages ongoing VAT reporting, ensuring that import VAT is correctly declared and deducted in your returns.

How do businesses use the Article 23 license in practice?

With an Article 23 permit, the day‑to‑day process of managing import VAT is straightforward. Treat it as an accounting exercise rather than a cash transaction.

Here’s what that looks like in practice.

Clear goods through customs

When your shipment arrives, customs issues a UTB, which states the customs value of the goods. Under Article 23, the VAT field on the UTB shows 0, because you’re not paying VAT at the border. Keep the UTB on file, as proof of the value you need to declare.

Use the customs value, not the invoice value

The base for calculating VAT in your return is the customs value on the UTB, not the price on your supplier’s invoice. Customs valuations can include freight, insurance, or adjustments so using the invoice value can lead to an understatement or overstatement of VAT. Getting it wrong repeatedly can jeopardize your license.

Report in your VAT return

In your Dutch VAT return, enter the customs value in box 4a, labeled “supplies/services from countries outside the EU.” Calculate the VAT and add it to your output VAT. Right below that, claim the same amount as input VAT. If you’re fully taxable, the two entries cancel out and there’s nothing to pay.

Maintain documentation

Keep the UTB and related documents (e.g., transport contracts, purchase invoices) accessible. In an audit, the tax authorities will want to see that the amounts you declared match the customs data. Sloppy recordkeeping or using the wrong values can lead to corrections or even revocation of your permit.

There are limits to what Article 23 covers. Customs duties, excise taxes, and other levies still need to be paid on import. But for most goods, once you’ve set up your accounting correctly, using the permit is a matter of routine.

Why is the Dutch Article 23 approach unique in Europe?

Many EU countries offer some form of deferred import VAT, but the Dutch Article 23 scheme stands out.

Here’s what makes it unique:

• Broad access: Any business with a Dutch establishment can apply. Nonresidents gain entry through a tax representative. There’s no requirement for special authorizations or statuses. You just need to meet the standard eligibility criteria.

• Quarterly filing: Unlike countries that insist on monthly VAT returns to use postponed accounting, the Netherlands allows you to file quarterly. This reduces the administrative burden for small and midsize importers.

• Standard guarantee: A financial guarantee is always required, but the minimum is manageable. Other jurisdictions might demand higher guarantees or limit the scheme to trusted traders.

• No special status or Authorised Economic Operator (AEO): In some EU countries, deferred import VAT is restricted to companies with AEO status or other certifications. The Dutch scheme doesn’t have this kind of restriction, but it doesn’t sacrifice oversight either.

• Logistical synergy: The Netherlands combines this tax benefit with world‑class ports and warehousing. That infrastructure, coupled with the cash flow neutrality of Article 23, explains why many global businesses pick Dutch ports as their gateway into the EU.

Taken together, these features make the Dutch postponed accounting system more accessible and more impactful on cash flow than similar mechanisms in other European countries.

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