Administration per client Security against position Seven-year retention obligation

Custom software for fiscal representation and customs administration

As a fiscal representative you are jointly liable for your client's VAT, interest on tax, collection interest and fines. Under a general licence, that liability per calendar year is never higher than the amount of the security provided. That makes one question continuously relevant: how far does the current position stand from what you have deposited?

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What the licence requires of your administration

A fiscal representative with a general licence must be resident or established in the Netherlands, provide security in advance in an acceptable form such as a bank guarantee or a cash deposit, and keep the transactions for each foreign entrepreneur separately so that they can be checked easily. Invoices must show both your own VAT identification number and that of the foreign entrepreneur.

With a limited licence the position is different. You receive one separate VAT number as a sub-number, and under it you file the returns for all your foreign clients together. The ICP declaration also falls under your own VAT identification number, for all clients for whom you act in a limited capacity. Here too, transactions must be recorded separately for each foreign entrepreneur.

The administration must be organised so that the origin and destination of the goods can be shown easily and the tax due can be readily established. This is not an accounting requirement but a practical one: someone from outside must be able to trace the route of a consignment without you being present.

On the customs side the same line applies. A licence holder keeps records in a form approved by Customs, showing the identification, the customs status and the transfer of goods under the scheme. The retention period is seven years, and data may be held on other data carriers as long as it remains accessible within a reasonable time for supervision.

How we build this

The core is the client and the consignment. A consignment without a client is a file without an owner, and a client without consignments is a risk position nobody sees building up.

1
Separation per client

Every foreign entrepreneur gets their own administration within the same system, because the licence requires it.

2
The shipment as a trail

Arrival, declaration, storage, outcome and delivery are all linked to a single shipment, so origin and destination are visible without reconstruction.

3
Feeding the declaration

What is recorded appears in the VAT return and the ICP statement under the correct number, rather than being retyped into a separate list.

4
Position against security

The system continuously shows how the open position relates to the security provided, per client and in total.

What the software actually does

The separation per client carries the whole. What else you need depends on your licence type and on whether you also file customs declarations.

Administration per client

Transactions for each foreign entrepreneur separately, verifiable without anyone first having to learn your way of working.

Shipment from arrival to delivery

Documents, declarations and locations are attached to the shipment, so the goods' journey can be read along a single trail.

Declaration and ICP statement

Under the correct number, with the underlying entries alongside. For any question about an amount, the source is clickable.

Security and position side by side

Your liability is limited to what you have provided. You should also be able to see when the position is approaching that limit.

File for post-clearance audit

Checks after import and after export are carried out on your administration. We build it so that an inspector can follow the trail themselves.

Retention period monitored

Seven years, even when records have been moved to another archive. Remaining accessible is the requirement, not just keeping the records.

Who we build for

Who works with this differs by company. Four situations.

Fiscal representatives

For them, the administration is not a side issue but the foundation of the licence and the limit on their liability.

Customs agents and freight forwarders

They file declarations on behalf of others and must be able to show, in a post-clearance audit, what the declaration was based on.

Logistics service providers with a warehouse

They hold goods under a regime and must be able to demonstrate identification, status and transfer.

Foreign entrepreneurs with Dutch imports

They only see the result, but have an interest in the file underneath being correct.

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Technology and integrations

Licence conditions change, tariffs are revised and declaration formats follow their own rhythm. Rules, numbers and document types should be configurable and not hard-coded.

Separate administration per client Integration with your customs declaration system Document storage per shipment Configurable rules per licence type Position and security monitoring Roles for declarants, accounting and management Search by shipment, container and document Retention periods and archiving Export for after-the-fact audits Audit trail on every change

Why Appfront

Your liability is limited, but only if you can see the limit

The security sets the ceiling per calendar year. We make the position against that ceiling visible, rather than something to be calculated afterwards.

Verifiable without you being there

The requirement is that actions can be checked in a simple way. That is a requirement of the set-up, not of your memory.

Origin and destination are one trail

We build the shipment as the common thread, because the law requires that trail and accounting does not produce it automatically.

We do not file declarations for you

The fiscal judgement remains with you and your adviser. We build the administration on which that judgement rests.

Security and privacy

Your files contain commercial data from foreign clients: suppliers, buyers, values and volumes. Clients want that information kept separate from one another, and the licence requires that separation too. We set access per role and per client, show staff only the files they work on, and log every access. Integrations run through secure connections to your existing software.

On this topic, the reliability of each record is what matters. A declaration line that gets changed afterwards without a trace makes the whole file worth less during an inspection. We record amendments as unalterable entries with time and person, and a correction appears as a visible correction alongside the original line. How we handle security ourselves is set out in our information security policy.

Frequently asked questions about fiscal representation

With a general licence, you keep records for each overseas business, and invoices show both your own VAT identification number and the client's. With a limited licence, you receive one separate sub-number under which you file returns for all your clients together.

You are jointly liable for your client's VAT, late payment interest, collection interest and administrative penalties. With a general licence, that liability in any calendar year never exceeds the amount of the security provided.

With an Article 23 licence, the import VAT does not have to be paid to Customs. Instead, it is included in the VAT return you file on behalf of your client.

On the customs side, the retention period is seven years. Records may be moved to other storage media, provided they remain accessible within a reasonable time for supervision.

Checks after import and after export are carried out on the basis of the licence holder's records. Those records must show the identification, the customs status and the transfer of goods under the procedure.

CBAM is a separate regime with its own declaration. We have a dedicated page on CBAM declaration software.

How does your position compare with your security?

Pick one client and work out which VAT is currently outstanding that you are jointly liable for. If that takes an afternoon of calculating, you only see the limit once you have already passed it. We build this as a standalone application and as part of a broader custom software development project.

If your concern is your own records and the retention obligation that applies to them, look at software for the tax retention requirement and the app for receipts and documents.

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