What VAT does Amazon FBA in Europe trigger?
Storing stock in an Amazon fulfilment centre can make you a VAT-registered business in the country where the stock sits, whatever country the buyer lives in. Each extra storage country can require an additional VAT registration and local filings. The One Stop Shop (OSS) and Amazon’s marketplace role help with some sales, but neither automatically removes the storage-based obligation.
Stock location creates the obligation
Yes: with FBA, the country where your inventory is held can create a VAT obligation, even if you have never sold there before. Put simply, where the inventory is located, a tax obligation may also arise. With your own webshop, you know exactly where goods ship from. With FBA, Amazon may store, move and fulfil your products from different European warehouses, depending on the model you choose.
The stock stays yours even inside Amazon’s warehouse. If it moves from one country to another, it may count as a transfer of own goods for VAT purposes, which can create an obligation on its own. For example, stock in a German warehouse, or joining the Pan-EU programme requires a VAT number in each country you enable for storage, at least two.
What each FBA model triggers
| FBA MODEL | VAT CONSEQUENCE (per RSM Hungary) |
| Single-country FBA | Local VAT number and returns for sales within the storage country; OSS for B2C sales shipped to other EU countries. EU sellers also report the initial stock transfer at home. |
| Pan-European FBA | Stock in several countries means multiple VAT registrations and returns, and a significant administrative burden. It is the model with the greatest risk. |
| B2B sales via Amazon | The reverse charge may apply to the B2B sale, but VAT registration may still be required in the country where the stock is stored. This is because importing goods or transferring own goods into that country can trigger separate VAT registration and reporting obligations, independently of the subsequent B2B sale. |
Typical Pan-EU risks include multi-country registration, wrong treatment of own-goods movements, confusion between OSS and local returns, missed Intrastat reports, faulty invoicing settings and penalties for late registration. Errors often surface in a later tax audit, when penalties may be imposed retroactively for several years. In serious cases, Amazon may suspend the seller account.
OSS and the marketplace: what they do not cover
The One Stop Shop (OSS) allows businesses to declare VAT on certain cross-border B2C sales through a single Member State portal. The OSS return is supplementary and does not replace VAT returns required under domestic obligations. OSS generally does not cover local VAT obligations arising from stockholding and transfers of own goods under the current rules. However, from 1 July 2028, the EU’s VAT in the Digital Age (ViDA) reforms will extend OSS to cover transfers of own goods, while the call-off stock simplification will be withdrawn. Businesses should therefore consider the applicable rules and implementation timeline when assessing their VAT obligations.
Although Amazon may act as a deemed supplier for certain marketplace sales and play a role in some import transactions, this does not automatically remove the seller’s VAT responsibilities. Sellers must still assess where their stock is held, where VAT registrations are required, which sales model applies, and which VAT returns and reporting obligations remain due.
Four misconceptions that cause FBA VAT risk
“I have OSS, so I am covered.” OSS simplifies some B2C reporting. It does not replace local registrations where you hold stock.
“Amazon handles my VAT.” Amazon’s marketplace role does not remove the seller’s need to review storage locations, registrations, sales model and returns.
“The stock is with Amazon, so it is not my problem.” In FBA the inventory may still be the seller’s stock. A cross-border move can be a transfer of own goods, which may create an obligation by itself.
“I only sell in Germany, so I only need German VAT.” The country of sale and the country of storage are not always the same. Under Pan-European FBA, stock can appear in several countries, so a single-country sales plan can become a multi-country compliance task.
The US contrast
| $9.5bn · 41% of reported US remote sales tax collections came via marketplaces, 2021 | In 2021, 20 states reported about $9.5 billion in remote sales tax collections from marketplace sales, around 41% of the $23.1 billion in remote-sales collections reported by 33 states The two figures come from different sets of states, so 41% is indicative, not an exact share. |
Since the 2018 Wayfair decision, US states need no physical presence to require sales tax collection. By June 2021, all but one of the 45 states with a statewide sales tax, plus D.C., had moved primary collection duty from the seller to the marketplace facilitator, such as Amazon.
The EU has a similar rule. Since July 2021 Amazon accounts for VAT on B2C sales by non-EU sellers from EU stock. Unlike in the US, the seller must still register wherever stock is held, to report imports, stock transfers and the sale to Amazon.
Frequently asked questions
Does the place of sale or the place of storage decide the VAT obligation? The logistics behind FBA can override the place-of-sale view, so you should check where the goods are stored, where they ship from and whether your own stock moves between Member States.
Is single-country FBA simpler? Generally yes. A local VAT number and local filings are generally sufficient, with OSS available for B2C sales. Pan-EU is the model with multiple registrations, multiple returns and the greatest risk.
What happens if the VAT set-up is wrong? Without the right registration, sales and invoicing may become impossible. Returns may go to the wrong country, and reports such as Intrastat or recapitulative statements may be missed. Penalties may follow retroactively after an audit, and Amazon may suspend the account.
Does the reverse charge in B2B sales remove the registration duty? No. The reverse charge may apply, but it does not exempt the business from registering in the country where the stock is stored.
Why does the US figure matter for EU sellers? It shows how large marketplace-driven collection has become in the US. Sellers also bear the compliance costs, such as software and audits, and that some businesses could not comply by the effective dates and were exposed to liability for later sales.
