What is an EC sales list?
ECP stands for intra-Community supplies. In the return, you specify certain supplies of goods and services to business customers in other EU countries. You declare the VAT identification number and the relevant turnover per customer. The Dutch Tax and Customs Administration can exchange this data with other EU countries.
The return is an addition to your VAT return. Simply submitting the VAT return is therefore not sufficient if you have also supplied goods or services subject to ICP reporting. The official explanation can be found at EC sales listing when doing business with other EU countries.
When as a sole trader do you need to report ICP?
Many self-employed professionals provide a service to a business in another EU country. Consider regular advisory work for a Belgian company with a valid VAT ID. If, under the main rule, the service is taxed in the customer's country and the VAT is shifted to that customer, the service generally belongs in the ICP return. Services that are exempt there or fall under 0% are not included.
| Situation | EC sales list |
|---|---|
| Standard business service to an EU business customer; VAT reversed-charged to that customer | Yes, unless an exception applies, such as an exemption or 0% in the customer's country. |
| Goods from the Netherlands to a business customer in another EU country | Yes, if it is an intra-Community supply. |
| You are buying software or another service from an EU country | Not included in your EC Sales List return. Do, however, check the processing of the purchase in your VAT return. |
| Domestic invoice with Dutch VAT reversed | No. Domestic reverse charge is not an intra-Community supply. |
| A standard sale to a private EU customer | Not as a business ICP supply; check the rules for private individuals and possibly OSS. |
| A service to a customer outside the EU | No, the EC sales list applies to intra-Community supplies. |
The transfer of own goods to another EU country and call-off stock can also require a return. These are separate situations; therefore, a sales invoice to a customer is not the only possible trigger.
First check the customer and the type of service
Your customer's VAT identification number
Request the foreign VAT ID before you draw up the invoice. Check the number via VIES and save the result. If the number is incorrect or the details do not match, ask your customer for the correct details. The Tax and Customs Administration refers for this to the European verification of VAT identification numbers.
For a sole proprietorship, your own VAT ID is the number for your invoices and business contacts. Do not confuse this with your turnover tax number for contact with the Tax and Customs Administration. Read more about the difference between VAT ID and turnover tax number.
An EU address does not automatically mean reverse-charge VAT
For business services, the general rule of taxation where the customer is established often applies. You do not put Dutch VAT on such an invoice and you state that the VAT has been shifted (reverse-charged). However, services relating to real estate, admission to events and a few other types of services have their own rules regarding the place of supply. Check these before choosing a foreign VAT code.
Use the official explanation about services to customers in other EU countries and exempt services. Our article about btw reverse charge for sole traders also handles the invoice reference.
Example: advisory work for two EU clients
You have completed regular advisory work for two business EU clients in one quarter. The VAT numbers are valid, the clients are purchasing the services for business purposes, the VAT has been shifted to them, and no exception or exemption applies.
| Customer | Service revenue in the quarter | Statement |
|---|---|---|
| Belgian company | Two jobs: €1,200 and €800 | €2,000 with the Belgian VAT ID |
| German company | One commission: €1,500 | €1,500 with the German VAT ID |
In the EC Sales List, you declare the total per customer: €2,000 and €1,500 for services. The total is €3.500. If you have no other intra-Community supplies this quarter, this matches €3,500 in box 3b of your VAT return. This is the consideration for the services, not an amount of Dutch VAT payable.
Always check about the same period. Do you file your ICP monthly and VAT return quarterly? Then compare the total of the three monthly returns with section 3b of that quarter.
Which time period applies and when do you need to submit?
For an entrepreneur established in the Netherlands, the ICP return must be received within one month after the chosen period. For the third quarter of 2026, that is no later than 31 October 2026. This follows from the ICP explanatory notes 2026, section for entrepreneurs in the Netherlands.
- Services only: You may submit returns monthly or quarterly. The €50,000 threshold for goods does not apply to services.
- Goods: Quarterly returns are allowed if in that quarter and each of the four preceding quarters you did not exceed €50,000 in intra-Community supplies of goods.
- Above the freight threshold: The switch to monthly returns depends on the month in which you exceed the threshold.
- Annual statement This requires authorisation; you cannot choose this yourself because you have little turnover from abroad.
If you supply both goods and services, you may declare them separately, subject to certain conditions. If you combine them, you must follow the rules for goods. The full transitional rules can be found at ICP reporting period.
Invoice date or performance date?
For intra-Community supplies of goods, the invoice date is decisive. For intra-Community supplies of services, it is the period in which you provided the service that counts. A service completed in September does not, therefore, automatically shift to the fourth quarter simply because you issue the invoice in October.
Preparing and submitting an ICP declaration
- Select the appropriate performance option. Keep services, goods, purchases and sales to private individuals separate.
- Check the customer details. Collect VAT numbers, country codes and the corresponding verification details.
- Add up the amounts for each customer. Please use the correct time period and category for goods or services.
- Reconcile with your VAT return. Check for any differences with section 3b before you submit.
- Submit and check for receipt. That can be done via Mijn Belastingdienst Zakelijk, suitable accounting software or your tax service provider. Keep the return and confirmation of receipt.
In the case of goods, your records must also provide evidence that the goods have actually been transported to another EU country. A foreign VAT number alone is not sufficient for this purpose. See the administrative documents for EU deliveries.
Correcting an error is not the same as processing a credit note
If an amount was incorrect in a previous return, you should enter the correction in the next ICP, specifying the original period, VAT registration number and the amount to be added or deducted. Did you declare €900 when it should have been €700? In that case, the correction is −€200, not another €700.
A new credit note, arising, for example, from a price reduction, should be entered as explained in section 3, under the details of intra-Community supplies. It should therefore not automatically be included under the section for errors in a previous return. You should also check the effect on the VAT return. The explanatory notes on sections 2 and 3 makes this distinction.
What about KOR and OSS?
The Dutch KOR This does not constitute an automatic exemption for everything you do abroad. Assess where your supply is subject to tax and whether an exemption applies there. Turnover that is subject to tax in another country does not count towards the Dutch KOR threshold in the same way. See the official KOR terms and conditions.
The EU-SME scheme covers additional situations. For goods, this depends, among other things, on the country of departure and the exemption you apply there. Therefore, do not draw any conclusions regarding the EC sales list based solely on the ‘SME’ label. Check the Overlap between EU-KOR and intra-Community transactions.
Sales to consumers for which you use the one-stop shop system are part of a different process from business-to-business ICP services. The OSS declaration does not replace the mandatory ICP declaration for your business’s EU turnover.
Frequently Asked Questions
Do I need to submit a nil ICP return?
Have you got no intra-Community supplies, transfers of goods or necessary corrections to report for the period? Then you do not need to submit a nil ICP return. That is separate from a VAT return that you are required to submit: you must submit that even without turnover.
Do I complete an ICP return for an invoice from a foreign supplier?
No, your ICP declaration relates to the services you declare as a supplier, not to a standard purchase invoice. However, when purchasing from another EU country, Dutch VAT may still be payable, for example due to the reverse charge mechanism. See the explanation regarding purchase goods and services from other EU countries. Whether you can deduct that VAT depends on your right to deduct.
Should a private customer in Belgium be included in my EC sales list?
You do not record a standard sale to a private customer as a business ICP supply. Different VAT rules may apply, such as those for distance sales. New means of transport are a specific exception and require a separate assessment.
My software generates an ICP report. Am I done then?
A prepared overview is not yet a submitted return. Check the VAT codes, customer numbers, period and the reconciliation with the VAT return. After submission, also check whether the return has been accepted. Software might otherwise neatly copy incorrect data.
