Amazon FBA VAT in the EU

The rule that catches most sellers

There is one principle behind almost every FBA VAT problem: holding stock in a country creates a taxable presence for VAT there. A local sale made from local inventory is a domestic supply in that country, and domestic supplies require a local VAT registration.

This is not a threshold question. The €10,000 EU-wide threshold in Article 59c of Directive 2006/112/EC applies to cross-border distance sales dispatched from one Member State to consumers in another. It says nothing about where you are allowed to store goods. Once Amazon moves a pallet into a fulfilment centre in Poland, you are making Polish domestic supplies, and Poland expects a Polish VAT number.

For non-EU established sellers the position is starker still: most Member States apply no registration threshold at all to non-established businesses. The obligation begins with the first taxable supply.

If you take one thing from this page: OSS does not replace local registrations. It replaces returns for cross-border B2C sales. Inventory location is a separate question, and it is the one that determines how many VAT numbers you need.

How Amazon's programmes change your footprint

Which countries you end up registered in is largely decided by the fulfilment programme you accept, not by where your customers are.

Pan-European FBA

Amazon redistributes your inventory across fulfilment centres in multiple countries to shorten delivery times. Each country that receives stock becomes a country where you make domestic supplies. In practice this means registering in every country in the programme before enabling it.

Central Europe Programme (CEP)

Stock is placed in Germany, Poland and Czechia. Enabling CEP without Polish and Czech registrations is one of the most common causes of retrospective registration and back-filing work we see.

European Fulfilment Network (EFN)

Inventory stays in a single home country and is shipped cross-border to customers. Because dispatch is from one Member State to consumers in others, these are distance sales — reportable through OSS without extra local registrations. EFN is the only major programme that does not multiply your registration count.

Multi-Country Inventory (MCI)

You choose the storage countries yourself. Registration follows your choice.

Practical consequence: the cheapest compliance position is usually EFN plus OSS. Pan-EU and CEP buy delivery speed at the cost of a registration and filing obligation in every storage country, indefinitely.

Movements of your own stock between countries

When Amazon relocates your inventory from one Member State to another, that movement is a deemed intra-Community supply in the departure country and a deemed intra-Community acquisition in the arrival country. This follows from Article 17(1) of Directive 2006/112/EC, which treats a transfer of own goods as a supply for consideration.

Both legs must be reported:

• The dispatch is reported in the departure country's VAT return and EC Sales List
• The acquisition is reported in the arrival country's VAT return
• Both may count towards Intrastat thresholds in the respective countries

These movements produce no revenue, which is precisely why they get missed. Amazon's fulfilment reports record them; your VAT returns must too. Reconciling stock-movement reports against filed returns is one of the highest-yield checks in an FBA compliance review.

Marketplace deemed supplier rules

Since 1 July 2021, Article 14a of Directive 2006/112/EC makes the marketplace the deemed supplier — meaning Amazon, not you, accounts for the VAT on the sale to the consumer — in two situations:

1. Distance sales of imported goods in consignments not exceeding €150 intrinsic value
2. Any supply within the EU by a non-EU established seller to an EU consumer, regardless of value

In the second case the single sale is split into two for VAT purposes: a supply from you to Amazon (zero-rated, with the right to deduct) and a supply from Amazon to the consumer.

This is a frequent source of confusion, so state it plainly: the deemed supplier rules do not remove your registration obligation. If you are a non-EU seller holding stock in Germany, Amazon may account for the output VAT on the consumer sale, but you still hold German inventory, still make a supply to Amazon in Germany, still need a German VAT number, and still need to file German returns and recover your German import VAT.

Import VAT and getting it back

Goods entering the EU incur import VAT in the country of importation. Recovering it depends entirely on being the correct party on the customs declaration.

• You generally need to be the importer of record, holding an EU EORI number, with the import documentation in your name
• Import VAT is recovered through the VAT return of the country of importation, not through OSS
• Several Member States (the Netherlands' Article 23 licence being the best known) allow postponed accounting, so import VAT is declared and deducted on the same return rather than paid at the border and reclaimed later — a material cash-flow difference

Where a freight forwarder is named as importer instead of you, the deduction right sits with them, not you, and the VAT is usually lost. This is worth checking before it happens rather than after.

A workable sequence

1. Decide the fulfilment programme first — it determines the registration map, not the other way round
2. Register in every country that will hold stock, before inventory arrives
3. Register for OSS in your country of identification for cross-border B2C distance sales
4. Obtain an EORI number and settle who is importer of record
5. Check Intrastat thresholds in each storage country
6. Reconcile Amazon's stock-movement reports to your filed returns every period

Retrospective correction is possible everywhere, but it is consistently more expensive than registering on time — back-filings, interest, and in some jurisdictions penalties that scale with the delay.

Where Veroskat fits

Sweden is our specialism. If Swedish inventory is part of your FBA footprint, we handle the registration with Skatteverket, the ongoing returns, corrections and Intrastat, and correspondence with the authority directly in Swedish. For the other storage countries we work through a network of local advisors built over a decade.

We also do this as a subcontractor: if you are a VAT or accounting firm with an FBA client who has stock in Sweden and you have no local capability, we handle the Swedish leg under your flag.

Sources

• Council Directive 2006/112/EC, Articles 14a, 17(1), 33, 59c
• Council Implementing Regulation (EU) No 282/2011, as amended by Regulation (EU) 2019/2026
• Commission Explanatory Notes on the VAT e-commerce rules (September 2020)