Expanding your supply chain to the Netherlands? Avoid these VAT and customs pitfalls

The Netherlands is often the preferred gateway into Europe, thanks to its location, logistics infrastructure and attractive VAT and customs facilities. Yet in our experience, VAT and customs problems rarely start with an incorrectly filed return. They start much earlier, in decisions that look purely operational: who imports the goods, which Incoterms apply, how products are classified, how intercompany transactions are valued.

All of these decisions feed into the same customs and VAT position, which is why we treat them as one system. But the way they go wrong differs. Some cost you cash flow, some cost you your margin, some cost you your customer. Below are the pitfalls we encounter most often, and what is actually at stake in each of them.

The import setup: a cash flow question 

Besides the Port of Rotterdam and Schiphol Airport, the Netherlands offers facilities that few other EU countries can match. The best known is the Article 23 licence, which allows import VAT to be reported in the periodic VAT return rather than paid at the border. For a business importing millions of euros of goods per year, the difference between paying 21% at the border and reporting it in the return is a permanent working capital advantage.

There is a second benefit that is less visible but just as real. Without the licence, import VAT paid at the border has to be reclaimed through the VAT return, which typically leaves the business in a structural refund position. Sizeable or recurring refund claims attract scrutiny from the Dutch Tax Administration: refunds are routinely held pending questions, and the cash stays locked up while the review runs. With an Article 23 licence, the import VAT is reported and deducted in the same return, netting to zero. No refund position, no audit trigger, no waiting.

Neither advantage is automatic. Both depend on the right structure and registrations being in place before the first shipment arrives. Businesses that sort this out afterwards typically finance months of import VAT out of their own pocket first.

Customs value: the problem that surfaces years later  

The declared customs value looks final at the moment of import, but within international groups it often is not. Year-end transfer pricing adjustments can retroactively change the price of goods that were declared months earlier. If those adjustments never reach the customs administration, the group quietly builds up exposure with every shipment.

What makes this pitfall painful is the timing. Customs authorities can revisit declarations up to three years back (longer in some cases), so by the time an audit lands, the correction covers thousands of import declarations at once, with interest. This is why we review customs valuation and transfer pricing together rather than in separate silos.

Incoterms: who ends up holding the bill  

Incoterms are usually negotiated commercially, but they quietly assign the role of importer of record, and that role is where things go wrong.

Under DDP (Delivered Duty Paid), the seller may become the importer in a country where it has no registration and no practical route to recover the import VAT. Margin that looked healthy on paper evaporates. Under DAP (Delivered at Place), the risk shifts to the relationship: the customer is confronted with an unexpected invoice for import VAT and duties on delivery, which leads to refused shipments, delays and, in B2C, one-star reviews. In both cases the goods arrive; it is the commercial outcome that suffers.

Classification: small error, large multiplier 

 Assigning a tariff code looks like an administrative task, and for straightforward products it usually is. For composite goods, kits or innovative products it is anything but, and this is where the multiplier effect kicks in. A code that is a few percentage points off in duty rate, applied consistently across thousands of shipments, adds up to a retrospective assessment that dwarfs the original saving of not looking into it. Where classification is genuinely uncertain, a Binding Tariff Information (BTI) ruling settles the question for the entire EU.

The group of businesses for whom this matters has just grown considerably. Since 1 July 2026, the customs duty exemption for consignments up to EUR 150 has been abolished. E-commerce sellers and marketplaces that never had to think about tariff codes now face duties on every parcel entering the EU.

One team, one assessment  

 By the time customs questions land on someone's desk, the commercial decisions that created them have usually already been made. That is the pattern behind every pitfall above, and it is why we do not split these topics across separate advisers.

At Bol International, VAT advice, customs advisory and fiscal representation sit in one multidisciplinary team. Whether you are entering the European market, importing through Dutch ports or reviewing an existing supply chain, we assess the chain as a whole, from customs valuation and tariff classification to Incoterms, Article 23 licences and fiscal representation.

Because in international trade, the best VAT and customs solutions are created long before the goods reach the border.

In our experience, the most successful international supply chains are not only commercially efficient, they are also designed with VAT and customs in mind from the very beginning.