Selling to the EU From Outside It

COUNTRIESSelling to the EU From OutsideIt
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You are in Canada, or Brazil, or Singapore. You write a newsletter, you put a paid tier on it, and somebody in Portugal subscribes for nine euros a month.

That transaction may have created a tax obligation in the European Union. Not at some later point when you get bigger. Possibly with that first subscriber.

This is the least popular article on this blog and probably the most useful one, so it is worth being precise rather than dramatic about it.

The rule that surprises people

The EU taxes digital services where the customer is, not where the seller is.

That part is widely known. What is not is the second half: for a business established outside the EU, there is no registration threshold. EU-established sellers get a modest annual allowance before cross-border rules bite. Sellers outside the EU do not.

There is no revenue level below which this does not apply, which means “I only have four European subscribers” is not the defence it sounds like.

I am not your accountant and this is not tax advice. It is one specific fact that a lot of otherwise careful people have never been told, and it is easy to verify with somebody who is qualified to give you the rest.

What counts

The category is electronically supplied services: things delivered over a network, essentially automated, where the delivery would not happen without the technology.

A subscription to online content sits squarely inside it. A Ghost membership that unlocks posts is about as automated as a supply gets. Nobody at your end does anything when a member logs in.

The obvious boundary case, one-to-one consulting delivered over video, is not automated in the same way and is treated differently. If most of what you sell is your own time, the picture changes and this article is less relevant to you. If what you sell is access to writing, it is not.

Three routes, honestly compared

Register in each member state. Legally available. Nobody does this voluntarily, and it means a filing obligation in every country you have a subscriber in.

Register once under the non-Union One Stop Shop. A seller outside the EU picks one member state, registers there, and files a single return covering sales into all of them. That is what the scheme was built for and it is a real simplification.

It is also still a registration, a return on a schedule, records to keep, and a rate to apply correctly per country at checkout. If you would rather not think about VAT at all, this route requires you to think about VAT regularly, just in one place instead of twenty-seven.

Sell through a merchant of record. The provider is legally the seller. It charges the right rate for each buyer’s country, files its own returns, and pays you a settled amount. Your EU VAT obligation on those sales does not exist, because you did not make those sales.

Of the providers PayGlue connects, Polar, Paddle, Lemon Squeezy, Creem and Gumroad are all merchants of record. PayPal, Ko-fi and Patreon are not. The full explanation of what that means.

The comparison people get wrong

The usual objection to a merchant of record is the fee. It is higher than a plain processor’s, sometimes noticeably.

The comparison is not fee against fee. It is fee against registration, plus a return every quarter, plus the accountant who prepares it, plus knowing the correct rate for each member state, plus the hours you spend on all of that instead of writing.

For a publication making a few thousand a year from European readers, the merchant of record usually wins that comparison once your own time counts for anything at all. For something much larger, with a finance function that already files in several jurisdictions, it may not, and at that size you have people to ask.

What this has to do with Ghost

Directly, nothing. Ghost has no tax logic in it and has never pretended otherwise.

Indirectly, quite a lot. Ghost’s native billing runs on Stripe, and Stripe is a payment processor rather than a merchant of record. Running Ghost the way it ships means you are the seller of record for tax purposes, whether or not anybody told you.

For a publisher outside the EU with European readers, that is a decision that gets made by default, in the direction that creates the most work.

Moving the payment step to a provider you chose makes it a decision instead. Ghost keeps doing the part it is good at: tiers, gated posts, newsletters, the reader relationship. Something in between turns a completed payment into a membership. Every route for doing that is compared here.

What I can and cannot tell you

I can tell you how Ghost’s Stripe constraint works, because Ghost is open source and I have read the part that imposes it. And I can tell you what to do about it, because that is what I build.

Not remove it, though. Ghost still wants a Stripe account connected before it will show you its membership settings, and nothing I do changes that. What changes is who takes the payment, which is the half that decides your tax position. Stripe can stay connected and idle, or keep billing the subscribers it already has, while a merchant of record handles the sales where VAT is the question.

I cannot tell you which scheme suits your business, what your home country expects of you, or how any of this interacts with your local rules. Nobody writing a blog post can, and the ones who sound most confident about it are usually the ones who have not checked.

What is worth taking from here is narrow: the no-threshold point is real, it applies from the first sale, and one of your provider choices makes it somebody else’s job. That is enough to know before you take money from your first European reader, and it is a much cheaper thing to learn now than in two years.

Related: what merchant of record means in practice, and how the same question plays out for publishers in India.

Frequently asked

Is there a revenue threshold before EU VAT applies to me?

For a business established outside the EU selling digital services to EU consumers, no. The registration threshold that exists for EU-established sellers does not apply to you, which means the obligation can begin with your first subscriber rather than at some revenue level.

Does this apply to a paid newsletter?

A subscription to online content is generally treated as an electronically supplied service, which is the category these rules were written for. Automated delivery is the distinguishing feature, and a Ghost membership is about as automated as delivery gets.

How do I avoid registering in every country?

Two ways. Register once under the non-Union One Stop Shop scheme and file a single return covering all member states, or sell through a merchant of record that is the seller for tax purposes and files on its own behalf. The second removes the question rather than simplifying it.

How does the tax rate get decided?

By where the customer is, not where you are. Rates differ per member state, so the same subscription carries a different rate for a buyer in Dublin than for one in Berlin. Handling that yourself means collecting location evidence and applying the correct rate at checkout.

Does Ghost handle any of this?

None of it. Ghost has no tax logic at all and never claimed to. Where the money is taken is what decides your tax position, which makes it a provider question rather than a CMS question.