Dutch tax authorities GDPR

From 1 January 2019 the Dutch tax authorities must stop using the Citizen Service Number (BSN) in the VAT number of self-employed persons with a sole proprietorship. The Dutch Data Protection Authority has reported that the Tax and Customs Administration has no legal basis to use the citizen service number in the VAT identification number.

Citizen service number

The citizen service number (BSN) is a unique personal number for everyone who is registered in the Dutch Basic Persons Registration. It is a legal identification number to make communication between government and citizen easier. The advantage of a BSN is that citizens do not have to submit their personal data to every government organization every time. The national government warns to be careful with the BSN number in order to prevent fraud. For example, they recommend when making a copy of your passport / ID, to cover the citizen service number.

VAT number

In the Netherlands every company that is liable for VAT gets a VAT number from the Dutch tax authorities. By default, they used to issue to self-employed persons with a sole proprietorship a number that consisted of their citizen service number with the prefix NL and suffix B01. Because the VAT number must be mentioned on every invoice and website of entrepreneurs, everyone can see the citizen service number of a self-employed person.

Data protection authority

The data protection authority initiated an investigation into the use of the BSN number for VAT numbers. They concluded that there is no legal basis for the use of the BSN in the VAT number.

The General Data Protection Regulation (GDPR) prescribes that a law must explicitly state that personal data may be processed and used for a specific purpose. And according to the authorities this is not the case here. The General Provisions Civil Service Number (WABb) Act, which deals with the use of the BSN, says nothing about the use of the processing of the BSN in VAT numbers.

The Dutch Tax Authorities must stop using the BSN in the VAT number from 1 January 2019. If they do not, the AP can take enforcement measures.


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