There is a return most creators have never heard of until a letter arrives. The opgaaf intracommunautaire prestaties, known in practice as the ICP return, is the Dutch equivalent of an EC Sales List. It sits apart from your VAT return, it covers the same turnover, and it is mandatory in some situations and off limits in others.
That last part is why this article exists. We see both mistakes about equally often: creators who skip it when they should file, and creators who fill it in neatly for turnover that does not belong in it.
What the ICP return is
When you supply a service to a business in another EU country, the VAT charge shifts to that country. You charge 0% and the customer accounts for the VAT at home. That is the reverse charge.
To be able to check that shift, the Belastingdienst, the Dutch tax authority, wants to know who supplied what to whom. That is what the ICP return is for. Per period, per customer, you report:
- The customer's VAT identification number
- That customer's country
- The total amount you supplied to them in that period
Those figures are matched against what the customer declares at home. If they do not line up, a question follows. Usually to you, because you are the party at the start of the chain.
When you do have to file it
The ICP return covers supplies to businesses within the EU. For a creator that concretely means:
- A platform established in another EU country that gives you a VAT number from that country
- A brand deal with a company in, say, Germany, Belgium or Ireland
- An agency or management company in the EU that pays you
- Another creator or business in the EU you invoice
The rule of thumb: VAT reverse-charged to an EU customer means ICP. If your invoice says the VAT has been reverse-charged and the customer sits in the EU, that amount belongs in the return.
When you specifically must not file it
This is where it goes wrong most often. The ICP return exists only for the EU. Supply a customer outside the EU and your service falls outside Dutch VAT, so there is no ICP obligation. That turnover does not belong in the return.
For creators this matters because several of the large platforms are not in the EU. Put that turnover in your ICP anyway and you are reporting an intra-Community supply that does not exist, against a number that is wrong or that you invented to get the field filled. That is a mistake that stands out, because there is nobody at the other end confirming it.
So the order is: first establish where your customer is established, then decide whether there is an ICP obligation. Never the other way round. How to determine that per platform is in VAT on your OnlyFans income.
Your customer's VAT number is the key
An ICP return without a valid VAT identification number for the customer does not work. You cannot leave it blank and you cannot put in something plausible.
What you therefore need from every EU customer:
- The full VAT identification number, including the country code
- The legal name of the entity, not the brand name
- Confirmation that the number is valid, which you can check in the European VIES system
That check is not the fussiness of a cautious accountant. If your customer's number turns out to be invalid, the reverse charge can be contested and the VAT can land back with you. On turnover in the tens of thousands, that is an assessment you did not budget for. Check the number when the working relationship starts, and again once a year has passed.
Period and deadline
The ICP return runs in principle in step with your VAT return, so quarterly, with the same deadline: the last day of the month following the quarter. In certain situations a different frequency applies, for instance at high amounts.
Important: in a period with no EU supplies you do not file at all. That differs from the VAT return, where a nil return is still required. That difference explains part of the confusion: creators who file no ICP because there was nothing, and creators who send in a nil ICP because that is what they are used to for VAT.
What happens if you skip it
Not an immediate disaster, but a chain you set in motion yourself:
- A penalty can follow for filing late or not at all
- The reconciliation with what your customer declares is missing, which prompts a question
- In a discussion about the reverse charge, the VAT can still be assessed after the fact
That last one is the real risk. The penalty is manageable; an assessment for VAT on turnover you have already paid tax on is not.
A worked example
A creator has two income streams. A large platform outside the EU, good for 11,400 euro in a quarter. And two brand deals with a German company, 2,800 euro together.
The correct treatment: both amounts appear in the VAT return, each in the box that belongs to it. The ICP return contains only the 2,800 euro, with the German VAT number against it. The 11,400 euro does not belong there.
The mistake we see most often: the full 14,200 euro in the ICP against the German party's VAT number, because that was the only number the creator had. That leaves one return carrying 11,400 euro that never surfaces at the other end.
Checking the VIES number, and why that is not overkill
Your EU customer's VAT identification number is the only ground the reverse charge stands on. If that number is invalid, or was invalid at the moment of supply, the reverse charge can be contested and the VAT comes back to you.
That is not a theoretical risk. On 30,000 euro of turnover to an EU customer where the reverse charge does not hold, you are talking about more than 6,000 euro you can no longer collect from that customer because the invoices are already paid.
The check takes two minutes in the European VIES system. What to record:
- The number you checked
- The date of the check
- The outcome, preferably as a screenshot or as the reference number VIES returns
Do it when a working relationship starts, and again after a year or whenever the customer changes entity. That record is what keeps a discussion short.
Correcting an earlier return
If a return you already filed turns out to be wrong, you can correct it. That happens more often than you would think, and the causes are usually these three:
- A credit note or reversal after the period in which you reported the supply
- An amount reported in the wrong period, typically around a quarter boundary
- Turnover allocated to the wrong VAT number
Correcting is a routine act, not a confession. What you should not do is "even out" a mistake in a later period by reporting a lower or higher amount there. Then two periods are wrong instead of one, and the reconciliation with what your customer declares fails in both.
What the ICP is not
Three confusions we regularly have to clear up, because each of them leads to a return reporting something that does not belong in it:
- It is not the VAT return. Two separate obligations over the same turnover. Doing one of the two is not enough.
- It is not for goods you buy. The ICP covers what you supply. What you buy in from another EU country runs through your VAT return.
- It is not for supplies to consumers. If you sell something to consumers in the EU, the rules for digital services to consumers apply, with their own thresholds, and that is a separate track.
Frequently asked questions
I have never filed an ICP return and I work with a German brand. What now?
Then there are periods you can still complete. A missed return can be filed after the fact, and that is almost always the better route than waiting for a letter. See putting a backlog of returns right.
How do I know whether my platform is in the EU?
Look at the legal entity on your payout statement or in your agreement, not at the app or the website. That entity's address is what decides it, and it can change.
Do I have to file the ICP for the commission the platform withholds?
No. The ICP covers what you supply, not what you buy. The treatment of services bought in from another country runs through your VAT return.
Can I do this myself?
Technically yes, it is a form. In practice the risk is not in the filling in but in the question of which turnover belongs in it, and that is exactly the part that goes wrong.
Reconciling your VAT return with your ICP
The two returns are laid against each other. The amount you report in your VAT return as a supply with VAT reverse-charged to an EU customer should equal the total of your ICP return for the same period.
If it differs, a question follows, and the cause is almost always one of three: turnover from a non-EU customer sitting in the wrong box of the VAT return, a supply that is in the ICP but reported under a different rate in the VAT return, or a correction processed in one return and not the other.
That check takes a minute per quarter, and it is why we always close the two side by side rather than one after the other. A difference you find yourself is a correction; a difference that gets found is a letter.
In closing
The ICP return is small work with a sharp edge. It applies to EU customers and only to EU customers, and your customer's VAT number is the only thing that makes it valid.
We handle the VAT return and, where needed, the ICP for creators on OnlyFans, F2F, Twitch and YouTube and other platforms.