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One thing I would love to know more about is how European SAAS startups handle invoicing and taxes. Afaik the tax situation in Europe is super complicated and y
by HugThem 9y ago
One thing I would love to know more about is how European SAAS startups handle invoicing and taxes. Afaik the tax situation in Europe is super complicated and you have to charge the tax of the country the customer is from.
I am in Europe and want to start a SAAS service that caters to individuals and small companies. I wonder if it is feasible to do so in Europe. Do I really have to ask each customer where he is based, if he is an individual or a company and then tax him accordingly? Do I have to create invoices?
US based startups seem to simply not care. Even big companies don't. They just ask for your credit card number and thats it. For example I used Amazon Mechanical Turk recently to outsource some work. And there simply is no way to get an invoice from them.
Do European startups have a big disadvantage in this regard or am I missing something?
Are there services that abstract that away? Deal with all the invoicing and tax issues?
- Xeoncross 9y agoAdd to that the additional questions about accepting crypto currency payments.
- zerostar07 9y agodo you know anything about it? I would like to tinker with something like that, but how does it work
- meredydd 9y agoThe tax stuff is a bit of a pain, but you can buy things (eg Stripe plugins) to make collecting the necessary data much smoother. In short: If you're supplying digital services to consumers, you need to charge them Value-Added Tax (VAT) in the country they're in, not the country you're in. If you're supplying to businesses, you charge them VAT where you are. You need to collect certain evidence with each transaction, to prove which category/country your customer is in. The search term you probably want is "VAT MOSS". This officially refers to the "Mini One-Stop Shop" provided by HMRC (the British tax authorities), which tries to ameliorate the situation. You still need to charge people the right amount of tax, but then you can just upload a quarterly spreadsheet saying how much revenue you got from each EU country. But "VAT MOSS" is also used as a catch-all term for the whole cross-border digital VAT kerfuffle. It started out as a well-intentioned attempt to close a tax loophole, but it was clearly drafted by people with no understanding of how computers work. (There are actually "FAQs" about how, precisely, to handle a German citizen with a British SIM card making a mobile transaction from a train journey crossing the Italian-Swiss border...as if this were something a website could reasonably detect.) But, as I say, there are decent solutions you can use, and you just spend a couple of days implementing one of them.
- Silhouette 9y agoBut, as I say, there are decent solutions you can use, and you just spend a couple of days implementing one of them. A couple of days seems very optimistic! The situation today is certainly better than it was for those of us who got hit by the new rules before the payment services had caught up and had to do it all ourselves. However, even the payment services today typically concentrate on adding the correct VAT rate onto initial purchases and possibly doing some sort of look-up to try to keep the required proof of location. They still won't do much to help you keep up to date with different tax rates for different types of service or in different territories, filing (and, if necessary, later re-filing) the MOSS returns themselves, knowing which location and therefore which tax rate to use for later payments after a customer starts an automatic recurring subscription of some kind, and so on. And of course it's all relatively simple if you collect all your payments through the same payment method, such as Stripe and a plugin as you mentioned. If you're collecting through different channels then you're still going to have to reconcile all the figures yourself as well, at least with any payment systems I've ever seen.
- SolarNet 9y ago> as if this were something a website could reasonably detect. Do you not record your users' GPS, connection point, roundtrip delay, microphone, and camera at all times? Because I stepped into a restaurant the other day and my brand new Android phone asked me to take a picture of the specific booth I had sat down in (by number and floor plan) for Google. Get with the modern analytics stack bro.
- scoot 9y ago> ameliorate the situation You could probably ameliorate that by changing it to "improve".
- meredydd 9y agoI intended the connotation of the word I used. It feels like the MOSS scheme's heart is in the right place, but the best they can do is make a bad situation suck a little less, and "ameliorate" is about as polite as I felt like being. (While I'm making a new comment, and since the last one is out of its edit window, I should acknowledge I mangled my attempt to summarise the place-of-supply rules. Sorry. Don't get your tax advice from HN comments, kids.)
- beberlei 9y agoyes, it is much more complicated in Europe, but you can rent software that handles most of it (and you should). If you cater to companies, it is easier. You ask for the VAT number and only if the company is from your own country, you add the VAT, otherwise its 0%. If you cater to individuals, you need to use two different mechanisms to identify where the user is from (IP Address + Geo location and another one) and store this information, then you need to charge the VAT from that country and you need to signup for the EU Mini One Stop Shop (MoSS) with your local tax office, report your european VAT earnings quarterly. Selling to a customer (business or individual) from outside the EU you can charge 0% VAT, so that is easy as well. I recommend that you use either Recurly or Quaderno in combination with Stripe, because they generate the invoices for you and handle the VAT calculation perfectly. I don't know about other countries than Germany (were we are located), but we also have to submit monthly VAT report to our tax office, all in all we pay our tax attorney 400-500 Euros per month, plus another 1000 for the yearly report. Maybe other EU countries allow startups to report quarterly or yearly? Idk.
- Silhouette 9y agoMaybe other EU countries allow startups to report quarterly or yearly? In the UK it's usually quarterly, but you have to file separate returns and make separate payments for VAT MOSS and domestic (UK) VAT, which might be out of phase unless your VAT quarters happen to fall on calendar quarters anyway.
- jacquesm 9y ago> You ask for the VAT number and only if the company is from your own country, you add the VAT, otherwise its 0%. No, it is not 0%, it is VAT deferred.
- GordonS 9y agoI think the correct term you are looking for is "zero rated". I mean to help others with their Googling, I'm not trying to be overly pedantic :)
- 9y ago
- Strom 9y agoYeah you have to do all that you mentioned, and more. For example, with EU SaaS sales to individuals, it doesn't matter where the customer lives or what citizenship they have, what matters is where they are at the moment of the sale. There is an endless supply of people who are willing to do this work for you, for a fee. Essentially this is the classic get an accountant advice. You could also do all of this yourself if you consider yourself smart and limited on cash. Frankly it isn't that complicated to understand. There's plenty of information available online. In my case (Estonia) the local tax authority is even giving regular education classes for free that you can attend.
- Silhouette 9y agoYou could also do all of this yourself if you consider yourself smart and limited on cash. Frankly it isn't that complicated to understand. The basic principle is easy enough to understand. I doubt that there is a single person alive who fully understands the technicalities, and I doubt that there is a single person who worked on the scheme at the EU who understands why full compliance is essentially impossible for most if not all businesses.
- dkyc 9y agoRunning a Germany-based SaaS startup at some scale, so I feel confident to chime in. To put it bluntly, you're right. We have to do more work just to get started accepting money than our American counterparts. Yes, the insanely complex EU-VAT rules actually need to be followed. Yes, a lot of your customers will want to pay via bank transfer and not through credit card. Yes, the American folks will still want to pay in USD and not in EUR. We use ChargeBee (https://www.chargebee.com/ https://www.chargebee.com/) to abstract away most of the pain. I would greatly suggest using such a service (Recurly and Chargify are more enterprisey alternatives). We had a selfmade implementation before switching to ChargeBee, and one EU rule change caused us to have to re-issue all customer invoices for one quarter. Not fun. ChargeBee prevents you from doing the biggest blunders in taxation, and also allows you to keep track of invoices paid through credit card or through bank transfer (and specify the Dunning rules accordingly). Overall, I'd greatly recommend it.
- deleted 9y ago[deleted]
- HugThem 9y agoThanks for the info! I tried your site and I saw that it adds the VAT when the user selects their country. Since the order page makes network requests to ChargBee, I guess they provide all that functionalilty. Would you say ChargeBee is also a good solution for small one-time-payments? When you say it abstracts away 'most of the pain' - what pain is left?
- theseanstewart 9y ago> Would you say ChargeBee is also a good solution for small one-time-payments? My startup uses ChargeBee and deals with one-time-payments as well as subscriptions. It's definitely geared towards the subscription model, but you can make the one-off payments work by using the API and utilizing add-on products. First, the customer would need to be signed up for a subscription plan that has a trial set to expire X years out (I think the maximum is 10). ChargeBee's pricing model is based on the total number of invoices per month (or at least that's how our plan works), so signing them up for a trial does not result in an invoice being generated. Then you would set up an add-on product in ChargeBee that is of the "Quantity" type and has a price of $.01. When the customer makes a one-off purchase, you would call use the ChargeBee API to purchase a quantity of X of the add-on. So if the total charge is $10, you would use a quantity of 1,000 (1,000 x .01 = 10). If you have products that have a set price, you can just add each one as an add-on and reference that product ID when calling the API. It sounds kind of hack-ey, but I'm very happy with our decision to go with ChargeBee. Their customer support is awesome as well.
- seanwilson 9y ago> Afaik the tax situation in Europe is super complicated and you have to charge the tax of the country the customer is from. What's the relational behind such a complex tax system? Sounds like a good way to discourage people from trying out business ideas.
- Diederich 9y agoThe EU is...complicated: https://www.youtube.com/watch?v=O37yJBFRrfg https://www.youtube.com/watch?v=O37yJBFRrfg
- tlb 9y agoIt's an improvement over the pre-EU situation, where every country was independent and shipping something 100 miles to a neighboring country would require customs declarations and tariffs and possibly complying with different labeling laws, assuming the countries weren't actually at war with each other at the time. Tax authorities systematically underestimate how much they harm the economy through complexity.
- Silhouette 9y agoThe VAT MOSS scheme we're talking about (currently) only applies to digital services, not physical products. The problems you mentioned don't apply in this context. There is absolutely nothing about this scheme that is better than before it was introduced. Nothing. Several years after it was introduced, as others have noted, some of the payment handling services have kind of caught up, to the point where if you can use one of them then you'll probably fly under the radar. You'll still have to spend time/money on the integration itself. You almost certainly still won't be fully compliant, because 100% compliance is practically impossible. You'll potentially be giving up a significant chunk of your margin in extra fees. And you'll still have the extra paperwork to do and the potential for an expensive audit by any of 28 member states' tax authorities if your number comes up. But at least you can carry on doing business in the meantime and hope for the best. This tax scheme is my go-to example of what happens when politicians who see a problem but have no idea what they're doing try to fix the problem anyway. Your final sentence is right on point, sadly.
- j_s 9y agoA similar portion of the more general discussion yesterday: Dear SaaS vendors | https://news.ycombinator.com/item?id=16180545 https://news.ycombinator.com/item?id=16180545 >dtech: As an European, my biggest wish for most SaaS vendors is an alternative to credit cards payments. SEPA Direct Debit >throwaway2016a: Lack of PDF invoices
- jotm 9y agoYou can just start selling and deal with the problems afterwards.
- lukevdp 9y agoNot always a good idea when it comes to legal and tax issues. Some things can't be fixed later.
- TomMarius 9y agoNever do that inside the EU unless you call being sued, paying huge fines and having your assets seized a solvable problem.
- jotm 9y agoYeah, you're right. Always have everything legal figured out before even starting your business, especially in the EU, no matter the cost. Good advice that everyone should follow.
- baybal2 9y ago>Afaik the tax situation in Europe is super complicated and you have to charge the tax of the country the customer is from. This is why you have to keep in mind of possibility of setting up a fulfillment centre outside of EU economic area and countries with which EU has tax deals with, but on the border with it.
- zerostar07 9y agolike?
- baybal2 9y agoSay Turkey. Turkey post is not as good as Finland's or Sweden'spost on delivery speed, but if you are frustrated with taxes, it should do the job.
- freyfogle 9y agoEU SaaS founder here. It really is not as complicated as people are making it out to be, at least for digital services (I have no experience with physical products). Use a service like Quaderno https://quaderno.io https://quaderno.io for the invoicing, they plug into Stripe. Once you get that set up it's not a big issue.
- zerostar07 9y agoJust because you are paying someone to do the complicated things does not mean it is not complicated. Also, $150 per month may be pennies to you but not for people in easter EU countries, or for a student trying to make a business. And that's only for 2500 invoices per month, what if you have thousands of tiny amounts?
- raverbashing 9y ago> just because you are paying someone to do the complicated things does not mean it is not complicated Of course, but that applies to everything, web hosting, email hosting, etc > easter EU countries Eastern > what if you have thousands of tiny amounts The card companies are eating your profit already in this case.
- zerostar07 9y ago> but that applies to everything irrelevant. EU doesn't have complicated email system, it has complicated tax systems compared to anywhere else in the world. > card companies are eating your profit Also irrelevant. they might be paying in raiblocks i d still have the same problem.
- raverbashing 9y ago> EU doesn't have complicated email system, it has complicated tax systems compared to anywhere else in the world. I'm glad you've shown your lack of knowledge here, VAT on digital services has some complexity, but overall taxation in the EU is simpler than what a lot of other countries require.
- mixedbit 9y agoThe easiest thing to do from the accounting and complexity perspective is to use a reseller. We use paddle.com and are very happy with them. In such setup, reseller is selling your product/service and handles all the invoicing, per country tax calculation, etc. No matter how much you sell, you always get only a single invoice per month from the reseller, with only one entry - the cumulative sales from the month, which is very easy to account. If I understand correctly, Apple store also operates as a reseller (but Google Play doesn't). The drawback is that customers see your reseller company name in invoices, which can be problematic for some, but we haven't yet hear complains.
- samblr 9y agoSomething that can help. Thanks.
- NicoJuicy 9y agoIt's a pro and a con. You have less european competition, because it's a hassle
- zerostar07 9y agoOh dont get me started. It's impossible. I am an indie developer and want to sell virtual products to europeans. The easiest way to do it is to have an american company collect the payments and take a cut. Meanwhile, the EU is busy coming up with cookie laws. Thanks EU. ps. here is a startup that is supposed to help companies with this minefield: http://taxdoo.com http://taxdoo.com . We shouldnt need these things.
- dirtyaura 9y agoEU cookie laws might feel silly, but I’m really glad that EU politicians are erring on that end of the spectrum than taking the path the US has been walking with net neutrality and surveillance.
- TomMarius 9y agoThey don't feel silly, they are silly. It has literally just made the situation worse.
- raverbashing 9y agoWhat's silly is people tacking in the cookie notice even for 99% of the times they are not needed > Cookies clearly exempt from consent according to the EU advisory body on data protection- WP29pdf include: > user‑input cookies (session-id) such as first‑party cookies to keep track of the user's input when filling online forms, shopping carts, etc., for the duration of a session or persistent cookies limited to a few hours in some cases authentication cookies, to identify the user once he has logged in, for the duration of a session > user‑centric security cookies, used to detect authentication abuses, for a limited persistent duration multimedia content player cookies, used to store technical data to play back video or audio content, for the duration of a session > load‑balancing cookies, for the duration of session > user‑interface customisation cookies such as language or font preferences, for the duration of a session (or slightly longer) > third‑party social plug‑in content‑sharing cookies, for logged‑in members of a social network. http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm
- gingerlime 9y agoWe’re B2C selling globally. We implemented VAT ourselves on top of Stripe. It’s a pain though. But it’s not only VAT MESS as they call it. At least in Germany tax is complicated and bureaucratic with freelancers and corporation tax rules. If I could start fresh, I would probably set up a company in Singapore. Moving an existing business is FAR more complicated... There’s a pretty great post from the Ghost founder about it (on mobile so can’t look it up easily). Worth considering in my opinion.
- wtfstatists 9y agoThere’s a pretty great post from the Ghost founder about it (on mobile so can’t look it up easily). https://blog.ghost.org/moving-to-singapore/ https://blog.ghost.org/moving-to-singapore/