What does a freelancer’s VAT number prove?

The Tax Administration distinguishes two numbers. 

The VAT identification number, or btw-id, is used in business dealings with clients and service providers. A Dutch VAT ID consists of “NL”, nine digits, “B” and two digits. Use the number actually issued to the business; matching this format does not establish validity. 

The turnover-tax number, or omzetbelastingnummer/ob-nummer, is used for dealings with the Tax Administration. For a sole proprietor, it contains the citizen service number, or BSN. The public VAT ID does not. 

These numbers are not the same as a KVK registration number. Registration with KVK is normally followed by the Tax Administration’s assessment of VAT entrepreneurship.

No. VAT entrepreneurship, income-tax entrepreneurship and employment classification are different assessments. 

The Tax Administration’s VAT guidance considers independent economic activity, including acting in one’s own name, for one’s own account and responsibility, and bearing business risk. A person may be a VAT entrepreneur without qualifying as an entrepreneur for income tax. 

For employment classification, Deliveroo requires assessment of all relevant circumstances. Tax treatment can inform the entrepreneurship assessment, but VAT registration does not establish an absence of employment authority. 

The EU VAT case Van der Steen, C-355/06, illustrates the separate VAT independence question. The CJEU held that, in the circumstances concerned, a sole shareholder/director working under an employment contract in the company’s name and on its behalf was not personally carrying out an independent taxable activity. 

No. Determine the treatment of the actual service before invoicing. 

Ordinary taxable services. Apply the relevant VAT rules and invoice requirements, including the service provider’s VAT ID where required. A VAT number does not mean every service is taxed at 21%. 

Exempt services. Some services are exempt if the applicable conditions are met. Do not confuse exemption with the zero rate or reverse charging. 

Small businesses scheme (KOR). The Dutch KOR is available subject to its conditions, including the €20,000 annual turnover limit. Participation is not automatic merely because turnover is low. Participants do not charge VAT and cannot deduct VAT on their costs and investments. 

The Tax Administration explains that KOR participants generally need not issue invoices for VAT purposes. If they issue one, they indicate that an exemption applies. Cross-border transactions can still create specific obligations. 

Cross-border services. For many B2B services to business customers in another EU country, the customer accounts for VAT under reverse charging. The invoice normally needs both VAT IDs and a reverse-charge statement. Exceptions depend on the service and customer.

As of 3 November 2026, the Zelfstandigenwet remains a proposal. It seeks to clarify when independent work is possible through a self-employment test and a work-relationship test. 

The October 2026 explanatory memorandum includes an active VAT ID among the intended administrative characteristics to be specified in secondary legislation. Its general discussion also refers to a VAT ID “insofar as required”. 

It would therefore be too categorical to state that every freelancer without a VAT ID is necessarily excluded, regardless of the activity or applicable VAT rules. The final legislation and implementing provisions would need to be checked. 

Possessing a VAT ID would in any event not satisfy all the proposed conditions.

Check which functions the configured system supports. A useful process distinguishes the following matters. 

Business identity. Record the legal name, relevant business details, VAT ID and the source of the information. Check that the identifier relates to the contracting service provider. 

Validation. VIES checks VAT information for intra-EU transactions using national records. Retain the date, result and available reference. A valid response is not confirmation of employment status or the treatment of every invoice. 

Exceptions and unresolved results. An invalid VIES response may reflect a nonexistent number, missing intra-EU activation or incomplete registration. A technical error is different again. Check the number and seek appropriate confirmation instead of automatically labelling the freelancer non-compliant. 

The VAT position. Record any relevant exemption, KOR participation or reverse-charge basis and review changes. A VIES check does not verify all these matters. 

Limited verification indicators. A checkmark should state what was checked and when, such as “VAT ID validated through VIES on [date]”. It should not mean “independent status approved” or “all invoices correct”. 

Proportionate access. Do not routinely store the ob-number, BSN, full VAT returns or tax-account credentials in a client-facing dossier. Where supporting correspondence is needed, restrict access and remove unrelated personal information. 

Corrections and changes. Review records when the business changes legal form, registration changes or an assignment is found to be employment. The Tax Administration confirms that employment work is not independently supplied for VAT. Existing invoices, deductions and registrations may then need coordinated review.