Guides · Art and VAT

Moving art across EU borders: the VAT rules

Inside the EU single market there are no customs duties and no border checks on art, but VAT still has to be accounted for somewhere. Which country taxes the movement depends on who is selling, who is buying, and whether the dealer uses the margin scheme.

No customs inside the EU

Goods in free circulation in the EU move between member states without customs duty or formalities. A painting delivered from Paris to Madrid is not “imported” into Spain. Customs only matters when art enters or leaves the EU — see customs and import duties. Export licences for cultural goods are a separate matter (EU Regulation 116/2009 for exports outside the EU, and national heritage rules for movements within it).

Five common situations

1. A private collector moves their own art

A private individual who moves works they already own — for example when relocating from France to Spain — owes no VAT on the movement. VAT was settled when the works were bought, and moving one’s own goods is not a supply. Keep purchase invoices to show the works were acquired in the EU or properly imported.

2. A dealer sells to a private buyer in another member state, under the margin scheme

Most secondary-market art is sold by dealers and auction houses under the margin scheme (Articles 311–343 of the VAT Directive), where VAT is charged only on the dealer’s margin and is not shown on the invoice. The distance-selling rules do not apply to margin-scheme sales (Article 35), so VAT is due in the seller’s country, at that country’s standard rate on the margin, wherever the buyer lives.

3. A dealer sells to a private buyer under the normal rules

If the margin scheme is not used and the seller ships the work to a consumer in another member state, the sale is an intra-EU distance sale. Since 1 July 2021, once a business’s total cross-border distance sales in the EU exceed €10,000 a year, VAT is due in the buyer’s country at that country’s rate, usually declared through the One-Stop Shop (OSS). Below that threshold the seller may charge its own country’s VAT.

4. Sale between businesses (dealer to dealer, or to a company)

An intra-Community supply of goods to a VAT-registered business in another member state is exempt in the seller’s country (Article 138) if the buyer gives a valid VAT number and transport is evidenced. The buyer accounts for acquisition VAT in its own country. A dealer may instead sell under the margin scheme, in which case case 2 applies.

5. Art imported from outside the EU

Import VAT is due in the member state of import, and many member states apply a reduced rate to imported works of art (France, for example, applies 5.5%). That reduced import rate is one reason art is often imported through a particular member state. Temporary admission, ATA carnets and free zones can suspend import VAT — see freeport storage.

Reduced rates on art

The VAT Directive allows member states to apply a reduced rate to imports of works of art, to supplies by the artist or the artist’s heirs, and, optionally, to other supplies of works of art. Rates now vary considerably: Germany restored a 7% rate for supplies of works of art from 1 January 2025, and Italy cut its rate on works of art to 5% in 2025. Directive (EU) 2022/542 also changed the margin scheme from 1 January 2025: a dealer can no longer use the margin scheme to resell a work on which a reduced rate was applied when the dealer imported or bought it, and the optional 30% flat-rate margin was abolished. See VAT on art and luxury goods for the rate comparison.

Reviewed October 2026