Global sales: tax responsibilities for sales made on Hotmart

Expanding your business into international markets is a significant step and comes with its own set of challenges. In addition to the opportunity to explore a new market, it is important to ensure that your company is compliant with the applicable tax laws and regulations of the countries in which sales take place.

Considering the updates to Hotmart's business model, in which we act as an agent for creators (representing them to buyers, cocreators, and affiliates), you may have new responsibilities that are essential to allow you greater autonomy in managing your business. For more information, please read the article Global sales: what you need to know about Hotmart's business model updates.

In this article, we'll review the basic rules so that when you make a sale, you understand the applicable taxes and your responsibilities when selling digital products globally. 

Attention: The information provided in this article is for informational purposes only and should not, under any circumstances, be considered as tax advice or used for decision-making. This article may not have all the latest specific data and is not intended to exhaust the topic. We recommend consulting your accountant and/or lawyer to determine the tax requirements related to your business. 

What are the tax responsibilities for sales made on Hotmart?

With the updates to Hotmart's business model, already in effect in Colombia since January 1 and starting from July 1, 2024, for the other countries mentioned in this article, there are three scenarios where tax responsibilities may vary depending on certain factors:

1. Where the creator is responsible for managing taxes and/or issuing invoices.
2. Where Hotmart is responsible for managing taxes and/or issuing invoices.
3. Where the management of taxes and issuance of invoices continues as it is today.

These different scenarios exist because, in some regions, tax laws related to sales made through platforms like Hotmart determine that the platform itself must manage taxes and issue invoices for each sale.

Important: These changes do not apply to local sales made in Brazil.

How to determine the tax scenario for your sales

To understand which scenario each of your sales falls under, you need to consider the following factors:

• Location of the creator: the country where the creator's Hotmart account is registered.
• Nature of the creator's account: type of account registered on the platform, whether individual or business.
• Nature of the product: whose definition and consequent tax treatment may vary depending on the legislation of each country. For example, in sales to the European Union, we have the concept of ESS* (Electronically Supplied Services).
• Location of the buyer: the country and/or state to which the sale was made.

*Electronically Supplied Services (ESS), for tax purposes in the European Union, refer to services provided over the Internet or an automated electronic network that involve minimal human intervention (such as software downloads, online courses, or streaming services). All existing and new products will have ESS as the default setting. If you have any questions about defining the nature of your product, we recommend consulting your accountant or lawyer.

❯ Scenarios where the creator is responsible for managing taxes and/or issuing invoices

As we mentioned, scenarios can vary based on several factors. That's why we've created a descriptive table to help you understand each type of situation.

Attention: it's very important to consider the buyer's location, as this factor can vary with each sale and directly affect your tax responsibilities.

Scenario	Location of the Creator (Country registered in the Hotmart account)	Nature of the creator's Account	Nature of the product	Location of the buyer
1	European Union	Any (Individual or Business)	Supplied non-electronically (non-ESS)	European Union
2	Anywhere in the world, except the European Union	Any (Individual or Business)	Supplied non-electronically (non-ESS)	European Union
3	Mexico	Business	Any	Mexico
4	Colombia	Any (Individual or Business)	Any	Colombia
5	Anywhere in the world, except Colombia	Any (Individual or Business)	Any	Colombia

Click here to understand how to interpret the scenarios where the creator will be responsible for managing taxes and issuing invoices.
It's important to note that creators must be aware of the fiscal and tax responsibilities of their business as a whole, regardless of the scenarios in which Hotmart takes care of the fiscal and tax management for each sale.

• Scenario 1
  If your buyer is in the European Union and you, the creator, are also in the European Union, selling as an individual or business, a product classified as non-ESS, you, the creator, will be responsible for managing taxes and issuing invoices.
  
  
• Scenario 2
  If your buyer is in the European Union and you, the creator, are outside the European Union, selling as an individual or business, a product classified as non-ESS, you, the creator, will be responsible for managing taxes and issuing invoices.
  
  
• Scenario 3
  If your buyer is in Mexico and you, the creator, is also in Mexico, selling as a business, you, the creator, will be responsible for managing taxes and issuing invoices.
  
  
• Scenario 4
  If your buyer is in Colombia and you, the creator, is also in Colombia, selling as an individual or business, you, the creator, will be responsible for managing taxes and issuing invoices.
  
  
• Scenario 5
  If your buyer is in Colombia and you, the creator, are outside Colombia, selling as an individual or business, you, the creator, will be responsible for managing taxes and issuing invoices.

Issuing invoices for each sale is one of the potential tax responsibilities. To streamline this process, Hotmart has integrated with leading automatic invoicing platforms worldwide. For more information, check out the articles below:

• Issuing invoices with eNotas  (Article in Portuguese only)
• Issuing invoices with Alegra

❯ Scenarios where Hotmart is responsible for managing taxes and/or issuing invoices

As we mentioned, scenarios can vary based on several factors. For example, in some regions, the tax laws for sales made on platforms such as Hotmart require Hotmart to still manage the taxes and invoicing for each sale. That's why we've created a descriptive table to help you understand each type of situation.

Scenario	Location of the Creator (Country registered in the Hotmart account)	Nature of the creator's Account	Nature of the product	Location of the buyer
6	Mexico	Individual	Any	Mexico
7	European Union	Any (Individual or Business)	Electronically supplied (ESS)	European Union
8	Anywhere in the world, except the European Union	Any (Individual or Business)	Electronically supplied (ESS)	European Union
9	Anywhere in the world, including the United States	Any (Individual or Business)	Any	United States
10	Anywhere in the world, except Mexico	Any (Individual or Business)	Any	Mexico

Click here to understand the sale scenarios above, in which Hotmart will continue to manage taxes and issue invoices.

• Scenario 6
  If your buyer is in Mexico and you, the creator, is also in Mexico, selling as an individual (not a company), Hotmart will be responsible for managing taxes and issuing invoices.
  
  
• Scenario 7
  If your buyer is in the European Union and you, the creator, are also in the European Union, selling as an individual or business, a product classified as ESS, Hotmart will be responsible for managing taxes and issuing invoices.
  
  
• Scenario 8
  If your buyer is in the European Union and you, the creator, are outside the European Union, selling as an individual or business, a product classified as ESS, Hotmart will be responsible for managing taxes and issuing invoices.
  
  
• Scenario 9
  If your buyer is in the United States and you, the creator, are in the United States or outside the United States, selling as an individual or business, Hotmart will be responsible for managing taxes and issuing invoices
  
  
• Scenario 10
  If your buyer is in Mexico and you, the creator, are outside Mexico, selling as an individual or business, Hotmart will manage taxes and issue invoices.

❯ Scenario where tax management and invoice issuance remain unchanged

For all other regions, in addition to those described above, also become part of the new business model. The difference, for now, is that for these regions, the responsibility remains the same.

In which scenarios does Hotmart continue to issue the Self Billing report?

With the updates to the business model, Hotmart will only issue the Self Billing report for the following scenarios:

Scenario	Location of the Creator (Country registered in the Hotmart account)	Nature of the creator's Account	Nature of the product	Location of the buyer
1	European Union	Any (Individual or Business)	Electronically supplied (ESS)	European Union
2	Mexico	Individual	Any	Mexico

If you are a creator from the European Union, selling an ESS product to a buyer from the European Union; or a creator from Mexico, with the legal nature of an individual, you must issue an invoice to Hotmart BV, and then Hotmart will issue a receipt with the buyer's information. To find out how to access the self billing report, see this article.

Some countries have special rules that require Hotmart, as a platform, to be responsible for tax management and invoicing of sales made to buyers. However, this does not exempt creators from fulfilling tax obligations in their country of origin.

❯ How to identify the countries of your buyers

You can check detailed information about each transaction by accessing the Sales Report. To see the country selected at the time of purchase, follow these steps:

1. Log in to your Hotmart account here: https://app.hotmart.com/
2. Select Sales > My Sales from the left-side menu
3. Click on Export > Detailed Template 
4. In the exported report, locate the Country column: this column shows the country selected by the buyer at checkout.