VAT on Stock Movements in the EU: Your Obligations Move with Your Goods

Moving inventory from one EU warehouse to another may look like an internal logistics decision. No customer has purchased the goods, no sales invoice has been issued and the legal owner of the stock has not changed.

For VAT purposes, however, the movement can still create reportable transactions in two countries.

VAT on stock movements is particularly important for Amazon FBA sellers, businesses using Pan-European FBA, marketplace fulfilment networks and ecommerce companies working with several EU warehouses or third-party logistics providers.

A stock transfer may create:

• A deemed intra-Community supply in the country from which the goods leave.
• A deemed intra-Community acquisition in the country where the goods arrive.
• A need for VAT registration in the destination country.
• Local VAT return and recapitulative statement obligations.
• Intrastat reporting where the relevant national thresholds are exceeded.

Using the One Stop Shop does not normally remove these obligations. OSS is designed primarily for eligible cross-border B2C sales, not for transfers of a seller’s own inventory between EU countries. The European Commission describes OSS as a simplification for cross-border ecommerce supplies to consumers, while the EU VAT Directive treats certain transfers of business goods to another Member State as taxable transactions in their own right. European Commission guidance on OSS and Article 17 of the EU VAT Directive provide the underlying framework.

Key Takeaway on VAT on stock movements

When your own goods move from one EU country to another, the movement may have to be reported even though there is no external customer.

In the standard situation:

1. The departure country treats the transfer as a deemed intra-Community supply.
2. The arrival country treats it as a deemed intra-Community acquisition.
3. You usually need an appropriate VAT registration in the country where the stock arrives.
4. The departure transaction may need to appear in the local VAT return and EC Sales List or recapitulative statement.
5. The arrival transaction normally needs to appear in the destination country’s VAT return.
6. OSS cannot normally be used to report the movement.

Sellers should therefore reconcile warehouse movements separately from customer sales.

What is a transfer of own goods?

A transfer of own goods takes place when a business moves inventory belonging to it from one EU Member State to another without selling the goods to a separate customer.

The owner remains the same before and after the movement.

Common examples include:

• Amazon moving a seller’s products from Germany to Poland.
• A retailer transferring stock from a warehouse in France to a fulfilment centre in Spain.
• A business replenishing its Italian warehouse with goods held in the Netherlands.
• A Shopify seller moving inventory between two EU third-party logistics providers.
• A non-EU seller redistributing imported stock between several European warehouses.

Under the EU VAT Directive, a transfer by a taxable person of goods forming part of its business assets to another Member State is generally treated as a supply of goods for consideration. This creates a deemed transaction even where there is no sale and no change of ownership.

The purpose is to ensure that goods moved between countries are accounted for under the destination-based EU VAT system.

How VAT on stock movements works

A standard cross-border stock movement is divided into two VAT legs.

Leg one: deemed supply in the departure country

The first leg takes place in the country from which the goods are dispatched.

The business is treated as making an intra-Community supply to itself, using its VAT identification number in the destination country.

Subject to the relevant conditions, this deemed supply may be VAT-exempt in the departure country. However, exemption does not mean that the transaction can be ignored.

The seller may need to include the movement in:

• The departure country’s VAT return.
• The local EC Sales List or recapitulative statement.
• Intrastat dispatch reporting, where the national threshold is exceeded.
• Supporting VAT and transport records.

The exact form name, deadline and reporting frequency depend on the country.

Leg two: deemed acquisition in the arrival country

The second leg takes place in the country where the goods arrive.

The business is treated as making an intra-Community acquisition of its own goods. EU rules generally place the taxation of an intra-Community acquisition where the goods are located when the transport ends.

The acquisition may need to be declared in:

• The destination country’s VAT return.
• Intrastat arrivals reporting, where the national threshold is exceeded.
• Other local transaction reports, depending on the country.

Acquisition VAT may normally be deductible where the business has a full right to deduct and the local conditions are met. Even where the VAT effect is neutral, the reporting obligation remains important.

Does the movement appear in two EC Sales Lists?

Normally, no.

The deemed intra-Community supply is generally included in the recapitulative statement of the departure country. The corresponding acquisition is reported through the VAT return in the arrival country.

Some local reporting systems require additional transactional data, but that does not mean that the acquisition is filed through a second EC Sales List.

This distinction is important when checking whether both sides of a transfer have been reported correctly.

Practical example: Amazon moves stock from Germany to Poland

An ecommerce business is VAT-registered in Germany and Poland. It owns 500 units stored in an Amazon warehouse in Germany.

Amazon transfers 100 units to a fulfilment centre in Poland.

There is no customer sale at the time of the movement. Nevertheless, the transfer may create:

In Germany

• A deemed intra-Community supply.
• Reporting in the German VAT return.
• Reporting in the German recapitulative statement.
• Potential Intrastat dispatch reporting.

In Poland

• A deemed intra-Community acquisition.
• Reporting in the Polish VAT return.
• Potential Intrastat arrivals reporting.

Future sales from the Polish warehouse must then be classified according to where each customer is located. Domestic Polish sales, cross-border B2C sales and B2B sales may each follow different reporting routes.

The business must therefore distinguish between:

• The original movement from Germany to Poland.
• Later customer sales made from the Polish stock.

They are separate VAT events.

Sellers using multi-country Amazon fulfilment can find more detail in our guide to Amazon FBA VAT registration and EU stock storage.

Why OSS does not cover transfers of own goods

OSS simplifies the reporting of certain supplies to consumers. For example, an eligible cross-border distance sale from stock in Germany to a private customer in France may be reported through the Union OSS.

A warehouse transfer is different.

When stock moves from Germany to France before it is sold, there is no B2C customer transaction to report through OSS. The movement falls under the rules for transfers of business assets and intra-Community acquisitions.

This means an online seller may use OSS correctly for customer sales and still need:

• VAT registrations in its storage countries.
• Domestic VAT returns.
• Recapitulative statements.
• Stock movement reconciliation.
• Intrastat declarations where applicable.

OSS therefore operates alongside local VAT registrations rather than replacing them in multi-country storage structures.

Our One Stop Shop guide for online sellers explains which B2C transactions can be included in OSS and which local obligations remain outside the scheme.

Unsure whether your warehouse setup requires OSS, local VAT registrations or both? Contact hellotax to review your stock and sales flows and understand the next compliance steps.

When does stock storage trigger VAT registration?

Storing goods in an EU country is one of the clearest indicators that a local VAT registration may be required.

A seller will commonly need to examine local registration where it:

• Stores its own inventory in the country.
• Moves goods into the country from another EU Member State.
• Imports goods into the country in its own name.
• Makes domestic taxable supplies from local stock.
• Uses a fulfilment programme that allows inventory to be placed there.

There is normally no general turnover threshold that allows a foreign seller to ignore VAT registration simply because the stock value or sales volume is low.

This is different from the EU-wide €10,000 threshold for certain cross-border B2C sales and digital services. That threshold does not remove VAT obligations created by foreign stock storage.

For a broader explanation, see our guide to EU VAT thresholds and multi-country storage.

Which VAT number should be used?

A standard transfer normally involves two VAT registrations belonging to the same legal entity:

• The VAT number of the departure country.
• The VAT number of the destination country.

For example, a Spanish company moving goods from a German warehouse to a French warehouse may use:

• Its German VAT number for the deemed supply.
• Its French VAT number for the deemed acquisition.

Having a domestic VAT number does not always automatically mean that the number is valid for intra-EU transactions. Businesses should confirm that the registration is active for cross-border EU trade in the relevant national system and in VIES where applicable.

The European Commission’s VIES VAT number validation tool allows businesses to check whether a VAT number is registered for cross-border EU trade. VIES results are drawn from national VAT databases.

A VIES check confirms the status of a number at the time of the search. It does not confirm that past stock movements were reported correctly.

What records should sellers keep?

Warehouse and marketplace data should be reconciled with VAT filings.

Relevant records may include:

• Amazon VAT Transaction Reports.
• Amazon fulfilment and inventory movement reports.
• 3PL warehouse movement files.
• Transfer orders and delivery notes.
• Dispatch and arrival dates.
• Product quantities and stock values.
• Departure and destination warehouse addresses.
• VAT numbers used for each movement.
• Transport documentation.
• Local VAT returns.
• EC Sales Lists or recapitulative statements.
• Intrastat declarations.

The records should allow the seller to connect every physical movement with the relevant VAT treatment.

A VAT return prepared only from customer sales data may miss internal warehouse transfers. This is why marketplace movement reports should be reviewed separately.

A stock movement reconciliation checklist

Online sellers can use the following process each filing period.

1. List every stock location

Identify every country in which inventory was stored during the period.

Do not rely only on the fulfilment countries originally selected in the marketplace settings. Review where goods were actually held.

2. Extract cross-border movements

Download the relevant marketplace, ERP or warehouse reports.

Filter for movements where:

• The departure and arrival countries differ.
• The goods remain owned by the same business.
• No separate customer sale occurred during the movement.

3. Match the VAT registrations

Confirm that the business had the necessary VAT numbers for both countries at the date of the movement.

Check whether the numbers were active for intra-EU transactions.

4. Match the departure reporting

Confirm that the deemed supply was included in the correct:

• VAT return.
• EC Sales List or recapitulative statement.
• Intrastat declaration, where required.

5. Match the arrival reporting

Confirm that the deemed acquisition was included in the destination VAT return and any applicable statistical or transactional report.

6. Investigate unmatched movements

Look for cases where:

• The departure leg was reported but the acquisition was missing.
• The acquisition was reported but the departure leg was missing.
• Neither side was reported.
• The wrong VAT number was used.
• The value or period differs between the two countries.
• A stock movement was incorrectly treated as a customer sale.

7. Correct errors through the local process

Correction procedures differ by Member State. Depending on the country and period, the seller may need an amended return, supplementary declaration, voluntary disclosure or written explanation.

Cross-border warehouse data can be difficult to match across several local filings. Speak with hellotax to review your registrations, reporting footprint and possible gaps before submitting corrections.

Are all movements of goods treated this way?

Not every physical movement automatically follows the standard transfer-of-own-goods treatment.

Possible exceptions or special rules may apply to:

• Goods temporarily moved for certain services or work.
• Goods installed or assembled in another country.
• Goods sent under qualifying call-off stock arrangements.
• Goods moved for temporary use under specific conditions.
• Goods supplied on board ships, aircraft or trains.
• Goods covered by special customs or VAT procedures.
• Returned stock.
• Movements that are directly connected to an identified customer supply.

Call-off stock, in particular, has its own conditions and recordkeeping requirements. It should not be assumed that every movement to a customer-controlled warehouse qualifies.

The business must review why the goods moved, who controls them, how long they remain in the country and whether a customer was already identified.

Common VAT on stock movements mistakes

Treating the movement as “internal” and ignoring it

The absence of a customer invoice does not prevent a VAT reporting obligation. EU rules can treat the transfer as a deemed supply and acquisition.

Assuming OSS covers all EU activity

OSS covers eligible supplies to consumers. It does not currently function as a general return for warehouse transfers, domestic transactions, imports or all stock-country obligations.

Reporting only the arrival or departure leg

A mismatch can arise when one country’s transaction is recorded but the corresponding entry in the other country is missing.

Using a VAT number that is not active in VIES

A VAT number may exist in a national system without being active for intra-EU transactions. Sellers should confirm its cross-border status.

Checking sales reports but not movement reports

Customer transaction reports do not always provide a complete view of warehouse relocations.

Registering after the first movement

VAT registration may be required from the date the taxable activity begins. A later application does not automatically remove earlier filing obligations.

Deregistering while stock is still present

A business should confirm that inventory has left the country and that all final returns, movements and local sales have been reported before requesting deregistration.

What does ViDA change for stock movements?

The EU’s VAT in the Digital Age package introduces a new special scheme for transfers of own goods as part of the Single VAT Registration reforms.

The European Commission states that the ViDA implementation includes a new transfer-of-own-goods scheme intended to reduce the need for multiple registrations.

The principal transfer-of-own-goods simplification is scheduled to apply from 1 July 2028.

Until the new rules become applicable, sellers must continue following the current registration and reporting framework.

The 2028 reform also does not automatically eliminate historical liabilities. Missing returns or incorrectly reported movements from earlier periods remain subject to the correction procedures and limitation periods of the relevant country.

Businesses should therefore not postpone reviewing current stock movements in the expectation that ViDA will later remove the problem.

How hellotax can help

Multi-country ecommerce VAT requires more than identifying where customers are located. Sellers must also understand where goods are imported, stored, moved and sold.

hellotax can help online sellers:

• Review their EU warehouse and fulfilment structure.
• Identify countries where VAT registration may be required.
• Understand how OSS interacts with local VAT filings.
• Review VAT numbers and cross-border registration status.
• Organise marketplace transaction and stock movement data.
• Support the wider VAT registration and filing process.
• Suggest next steps where past stock movements may require investigation.

We do not assume that every warehouse movement produces the same result. The correct treatment depends on the countries involved, the reason for the movement, the seller’s registrations and the fulfilment arrangement.

Do you move stock between Amazon warehouses, 3PL locations or your own EU fulfilment centres? Contact hellotax to review how those movements fit into your VAT setup.

Summary: control the movement before filing the return

VAT on stock movements applies because EU VAT rules can treat a transfer of a business’s own goods as two linked transactions: a deemed supply in the departure country and a deemed acquisition in the arrival country.

For online sellers, the most important points are:

• A physical stock movement can be reportable without a customer sale.
• Local VAT registration may be required in the arrival country.
• The departure leg may need to appear in a VAT return and EC Sales List.
• The acquisition normally needs to appear in the destination VAT return.
• Intrastat may also apply when national thresholds are exceeded.
• OSS does not currently cover standard transfers of own goods.
• VIES confirms VAT-number status but does not confirm transaction reporting.
• Marketplace and warehouse reports should be reconciled with filings in both countries.
• ViDA is expected to simplify future transfers from July 2028, but current and historical obligations still need attention.

The safest approach is to map every country in which stock is held, identify every cross-border movement and verify that both VAT legs are reflected in the correct local reports.

Frequently Asked Questions

Does VAT on stock movements apply when I still own the goods?

Yes. A transfer of your own business goods from one EU country to another can be treated as a deemed intra-Community supply and acquisition even though ownership does not change.

Can I report stock movements through OSS?

Under the current rules, standard transfers of own goods are not normally reported through OSS. OSS covers eligible cross-border B2C sales and certain services. Local VAT registrations and returns may still be required for stock movements.

Do I need VAT registration in every country where Amazon stores my stock?

Local VAT registration is commonly required where your own inventory is stored and used for taxable activities. The exact position depends on the fulfilment arrangement and local rules, but there is normally no general sales threshold protecting a foreign seller from registration purely because the volume is low.

Does a stock movement have to be included in an EC Sales List?

The deemed intra-Community supply normally needs to be included in the EC Sales List or recapitulative statement of the departure country. The corresponding acquisition is generally declared in the destination country’s VAT return.

Is a valid VIES result enough to prove that my stock movements are compliant?

No. VIES confirms whether a VAT number is registered for cross-border EU trade at the time of the check. It does not show whether a particular transaction, VAT return or stock movement was reported.

What happens if a previous stock movement was not reported?

The correction process depends on the countries, reporting periods and forms involved. You may need amended VAT returns, corrected recapitulative statements or other voluntary corrections. The movement should be investigated on both the departure and arrival sides before corrections are filed.

Need help managing VAT on stock movements between EU warehouses? Contact hellotax to review your storage locations, VAT registrations and reporting obligations before missing movements create compliance issues.