EU VAT location evidence: how to prove where your customer was

Quick answer: For digital sales to EU consumers, the customer's country decides which VAT rate applies — so EU rules require you to collect and keep evidence of where each customer belongs. The general rule is two pieces of non-contradictory evidence (e.g. billing address + card-issuer country). If your cross-border digital sales stay under €100,000 a year, a single piece of third-party evidence is enough. You rarely have to produce it — but when an auditor asks, “how do you know they were in France?”, the evidence is the only answer that counts.

Why does your customer's location decide the VAT?

For digital services sold to EU consumers, the place of supply is the customer's country. Courses, templates, subscriptions, software — the country where the customer belongs sets which VAT rate applies and, once you pass the €10,000 pan-EU threshold, which country the VAT is owed to. So location isn't a detail on the receipt; it's the input that determines the entire tax treatment of the sale. That's exactly why the rules don't let you simply take the buyer's word for it.

What evidence do you need? The two-item rule

The general requirement is two pieces of non-contradictory evidence of where the customer belongs. Accepted items include the billing address, the device IP address, the country of the bank or card issuer, the SIM country code (for mobile purchases), and other commercially relevant information. You need two of these pointing at the same country and not contradicting each other. If the billing address says Italy but the card and IP say Germany, that's a discrepancy to resolve — not a sale you can quietly book at Italy's rate.

What's the small-seller simplification (under €100,000)?

If your cross-border digital-service sales to EU consumers stay under €100,000 a year, a single piece of third-party evidence is enough — for example, the card-issuer country. Most creators sit inside this simplification. But “one item” still means you must actively collect and keep that one item, per sale — it isn't a pass to keep nothing.

How long must you keep it?

OSS records must generally be kept for 10 years and produced on request. A CSV you exported once and later lost is not a record. The obligation is not just to have seen the evidence at checkout, but to be able to retrieve a per-sale record years later.

Why is this harder for creators than it looks?

The evidence usually exists — it's just scattered and unretrievable. Stripe knows the card country; your checkout saw the IP. But sell across Stripe, Gumroad, Substack and Patreon and you have four partial records of the same obligation, stored differently, none in a form you could hand an auditor per transaction. Two edges catch people out: retention (records must survive for years, not live in a lost export) and date of supply (the correct rate is the one in force when the service was supplied, not when you were paid — see our guide to date of supply vs payout date).

What should you actually do?

1. Capture location evidence on every sale — at least one third-party item under €100k, two if over. Billing country + card-issuer country is a common, defensible pair.
2. Store it consistently and per transaction, not as platform exports you'll never reconcile.
3. Keep it for the full retention period and make sure you could produce a per-sale record if asked.
4. Apply the rate at the date of supply, with the evidence attached to that determination.

How VatForge helps

VatForge keeps a consistent, per-transaction proof-of-location archive across every platform, with the correct rate applied at the date of supply. It pulls your sales into one ledger and keeps the location evidence attached to each sale, so being audit-ready is a state you're already in rather than a scramble later. It's advisory and EU-only: it prepares your records and your OSS return; you file it. This is also the trail that CESOP lets tax authorities check independently.

VatForge keeps your location evidence and OSS records audit-ready across every platform. See where you stand at vatforge.com.