When a VAT-registered business in Slovakia or Czechia sells goods across the border within the EU, the VAT treatment does not depend on the country but on who the buyer is. If the customer is a business with a valid VAT ID, the sale is an intra-Community supply exempt from home-country VAT and the buyer self-assesses the tax. If you sell to a consumer, you charge your own VAT until your EU-wide distance sales exceed 10,000 euros a year — after that you charge the customer country’s VAT through the OSS scheme.
Why does it matter who the buyer is?
The split between selling to a business (B2B) and to a consumer (B2C) is decisive, because each case carries a different VAT regime and different obligations. When you sell to a foreign business, the buyer ultimately accounts for the tax in their own country; when you sell to a consumer, the liability stays with you and only the applicable VAT rate changes.
The mechanics are harmonised across the EU by the VAT Directive, so the logic is the same in Bratislava and in Prague. What differs are the national rates and the domestic forms. Slovakia applies a standard VAT rate of 23%, while Czechia applies 21% — a difference that matters the moment you have to charge the destination country’s rate.
How does a supply to a VAT-registered business work?
A supply of goods to a customer registered for VAT in another member state is an intra-Community supply exempt with the right to deduct — in Slovakia under Section 43 of Act 222/2004, in Czechia under Section 64 of Act 235/2004. You invoice without VAT and the buyer self-assesses the acquisition in their return. You pay no output tax and keep your input VAT deduction.
The exemption is not automatic. Three conditions must be met at once: the buyer holds a valid VAT ID in another member state, the goods are physically transported out of your country, and you report the supply in the recapitulative statement (súhrnný výkaz in Slovakia, souhrnné hlášení in Czechia). Always verify the buyer’s number in VIES — an invalid ID is the single most common reason a tax office denies the exemption and assesses domestic VAT.
What applies when you sell to a consumer?
A sale to a private individual — typically through an e-shop — is a distance sale. Until the total of your distance sales to all EU countries in a calendar year exceeds 10,000 euros, you charge your home VAT (23% in Slovakia, 21% in Czechia) and pay it at home. This threshold is counted jointly for the whole EU, not per country.
Once you cross it, the place of supply moves to the customer’s country and you must charge that country’s VAT. To avoid registering in every state, you use the One-Stop Shop (OSS) and remit the tax for all countries in a single return. If you need broader guidance on running a business across both jurisdictions, our team’s tax advisory overview is a good starting point.
How do you invoice a cross-border sale correctly?
An invoice for an intra-Community supply must show both your VAT ID and the buyer’s VAT ID and, instead of a rate and amount of tax, a note that the supply is exempt and the tax is payable by the customer, with a reference to the relevant provision. Without both valid numbers and this note, the invoice does not stand up formally.
Example: a Slovak wholesaler sells components to a Czech company with a valid VAT ID for 8,000 euros. It issues an invoice without VAT, showing both numbers and the exemption note, ships the goods to Brno and reports the supply in its recapitulative statement. The Czech buyer accounts for the acquisition VAT at home. In Czechia the same invoice also feeds into the domestic control statement, which is cross-checked against the counterparty.
What documents prove the transport of goods?
The burden of proving that the goods actually left the country lies with the seller. If you cannot evidence the transport, the tax office will refuse the exemption even if the buyer was a genuine taxable person. Keep the transport and delivery documents with the invoice.
- a transport document (a CMR for road haulage, a courier consignment note) or a carrier’s confirmation;
- a delivery note signed by the buyer or a written confirmation that the goods were received in the other member state;
- proof of payment for transport and the order or contract showing the place of delivery.
Where the buyer arranges transport themselves, insist on a written statement that they received and transported the goods abroad — these are the cases most likely to be disputed.
What are the most common mistakes?
Most problems stem not from bad intent but from formal omissions, which tax offices detect from the data member states automatically exchange. The recurring errors are the same on both sides of the border: invoicing without VAT to a buyer with no valid ID; a missing or incorrect recapitulative statement; applying the wrong country’s rate; ignoring the 10,000-euro distance-sales threshold; and undocumented transport. A special case is storing goods in the destination country — for example in your own warehouse or a marketplace’s — which can trigger local VAT registration regardless of the threshold.
Selling goods across the EU border and unsure whether you invoice correctly or need to register abroad? We will review your specific transactions and set up VAT safely.
FAQ
Do I need to register for VAT in the destination country?
When selling to a business with a valid VAT ID you do not — it is an exempt intra-Community supply and the buyer accounts for the tax. When selling to consumers above the 10,000-euro threshold you charge the destination VAT through OSS, so a separate local registration is not needed either. Registration does arise if you store goods in that country or run a warehouse there.
What if the buyer’s VAT ID is invalid?
Without a valid VAT ID in another member state you cannot apply the exemption. The buyer is then treated as a non-taxable person, so you charge your home VAT (23% in Slovakia, 21% in Czechia) or, for distance sales above the threshold, the destination VAT via OSS. Always verify the number in VIES before issuing the invoice.
What exactly is the 10,000-euro threshold?
It is a single EU-wide limit for distance sales of goods to consumers, counted across all member states together for the calendar year. Below it you charge your home-country VAT; once your combined B2C cross-border sales exceed it, you must charge each customer their country’s VAT and typically declare it through the OSS one-stop shop.