Cross-border VAT exemption: selling into the EU from Luxembourg

In short. Since 1 January 2025, a small business established in Luxembourg can invoice without VAT in another EU member state, without registering there. Three conditions apply: annual EU-wide turnover below 100,000 €, compliance with the exemption threshold of the country you are selling into, and a prior notification to the Registration Duties, Estates and VAT Authority through MyGuichet.lu. In return you receive an identification number carrying the EX suffix and file a turnover report every quarter. This scheme is separate from the domestic exemption at 50,000 €.

A Luxembourg SME that starts selling into Belgium, France or Germany quickly hits the same wall: do I have to register for VAT in the customer's country? Until 2024 the answer was often yes, with all the administrative cost that implies for a few thousand euros of invoicing. The cross-border exemption scheme, in force since 1 January 2025, changes that calculation. It is still little known, which is precisely why it is worth a close look.

What is the cross-border VAT exemption?

The cross-border VAT exemption lets a small business established in one EU member state supply goods or services in another member state without charging VAT there and without registering there. It is restricted to businesses whose annual turnover across the whole EU stays below 100,000 €. It rests on a prior notification filed with the tax authority of the country of establishment.

Do not confuse the two schemes: they share a common name and cover different ground.

The domestic threshold of 50,000 €, raised on 1 January 2025, carries a 10 % tolerance, meaning 55,000 €, which lets you finish the current calendar year under the scheme. How that domestic exemption works is set out in our article on accountants for self-employed people and freelancers in Luxembourg.

The three conditions

To claim the cross-border exemption from Luxembourg, your business must meet all three of the following.

• Be established in Luxembourg and supply goods or services in another EU member state.
• Have annual EU turnover below 100,000 €. Note that this threshold is assessed across the whole Union, Luxembourg included, not country by country.
• Stay below the exemption threshold applicable in the country you are selling into. Each member state sets its own, and it differs from the Luxembourg figure. This is the most commonly overlooked point: eligibility in Germany tells you nothing about eligibility in France.

That double test, EU threshold and local threshold, is the main source of error. A business can sit comfortably below 100,000 € at European level while crossing the domestic threshold of a country where its sales are concentrated, and lose the exemption in that country alone.

Registering, in practice

The process runs online, with authentication by LuxTrust product or electronic identity card, from a MyGuichet.lu business space. You file a prior notification with the Registration Duties, Estates and VAT Authority, stating:

• the member state or states in which you intend to apply the exemption;
• the total value of your supplies, in Luxembourg and in each other member state, for the previous calendar year;
• the same figures for the current calendar year up to the date of notification.

Following that notification, the authority issues an individual identification number carrying the EX suffix. One point of timing matters: the exemption applies in the other member state only from the date the AED communicates that number, not from the date you filed. Invoices raised in between fall outside the scheme. File before your first sale, not after it.

Obligations once registered

The quarterly report

This is the trade-off, and it is more demanding than it looks. Each quarter you report to the AED your turnover in every member state, including turnover generated in Luxembourg. If you sold nothing in a given country, you report "0": the filing is not suspended for want of activity. Deadlines are fixed at one month after the end of the calendar quarter.

Crossing the threshold

If your EU turnover passes 100,000 € during the year, the exemption stops applying in the other member states from the day after it is crossed. You then have 15 working days to inform the AED, stating the exact date, and to report the amounts generated between the start of the current quarter and that date. In practice this means tracking your European turnover continuously rather than discovering it at year-end.

Does the scheme actually help you?

This is the question a firm should put to you before registering, and few do. The cross-border exemption saves you a foreign VAT registration and the filing burden attached to it. In exchange, it removes your right to deduct input VAT on the related purchases, and it imposes quarterly European reporting.

The logic is straightforward. If you sell services to private customers in another member state with few upstream purchases, the scheme almost always wins: you avoid a costly registration for a modest volume. If you sell to VAT-registered businesses, the reverse charge mechanism often settles the question already, as we explain in our article on intra-EU VAT in Luxembourg. And if you are investing heavily in equipment, subcontracting or stock, the loss of input VAT recovery can outweigh the administrative saving.

A final note of caution: the scheme is young. Administrative practice across member states is still settling, and national thresholds move. Treat a decision to register as a management decision to revisit each year, not a permanent choice.

Tracking it properly in your accounts

The real risk here is not legal but operational: producing, every quarter, a turnover figure broken down by country. Books kept in arrears make that exercise painful and approximate, and a rough figure exposes you on a scheme whose eligibility turns precisely on thresholds.

At Advena we keep your books in the Odoo we have configured for Luxembourg VAT, which makes that breakdown immediate: fiscal positions are set at configuration, every invoice carries its country of destination, and turnover by member state reads off without reprocessing. You therefore know where you stand against the 100,000 € at any moment, not only at quarter-end. The underlying accounting setup is described in our article on Luxembourg accounting in Odoo, and the wider framework in our guide to accounting firms in Luxembourg. All of it sits inside the fixed fee, from 325 € per month, with no hourly billing: a question about a threshold costs you nothing extra.

One honest qualification: we advise on the Luxembourg framework. If your activity spreads across several member states with permanent establishment or transfer pricing at stake, that is beyond our remit and we will point you elsewhere rather than improvise.

Frequently asked questions

What is the threshold for the cross-border VAT exemption?

Annual turnover across the whole European Union, Luxembourg included, must not exceed 100,000 €. You must also stay below the exemption threshold applicable in each member state where you wish to use the scheme.

What is the difference between the domestic and cross-border exemptions?

The domestic exemption covers Luxembourg businesses operating solely in Luxembourg, up to 50,000 € of turnover with a 10 % tolerance. The cross-border exemption covers supplies made in another member state and rests on a European threshold of 100,000 € plus a prior notification.

What is the EX-suffix VAT number?

It is the individual identification number issued by the Registration Duties, Estates and VAT Authority following your prior notification. The exemption applies in the other member state only from the date that number is communicated to you.

What filings does the scheme require?

A quarterly turnover report through MyGuichet.lu, due by 30 April, 31 July, 31 October and 31 January. It covers turnover generated in Luxembourg and in each other member state, including nil returns.

What happens if I exceed 100,000 €?

The exemption stops applying in the other member states from the day after the threshold is crossed. You must inform the authority within 15 working days, stating the date and the amounts generated since the start of the current quarter.

Read next

• Accounting firm in Luxembourg: the complete guide for an SME
• Intra-EU VAT in Luxembourg: reverse charge and recapitulative statements
• Luxembourg VAT returns: filing frequency, eCDF and deadlines
• An accountant for self-employed and freelancers in Luxembourg
• What an accounting firm costs in Luxembourg

Why Advena?

We keep the books of Luxembourg SMEs inside the management system we deploy ourselves, which turns the tracking of a European threshold into a live figure rather than a quarterly scramble. Fixed fee from 325 € per month, a named account manager, accounts kept current, and no billing outside the monthly fee. The rules described here come from the official publications of Guichet.lu and the indirect taxation portal, consulted in July 2026; as the scheme is recent, check the thresholds applicable in the target country before deciding.