Moving Your Own Goods Between EU Warehouses

For VAT purposes, however, moving own goods between EU warehouses may have consequences that should be reviewed before the first shipment leaves Bulgaria. 🙂

Why can moving your own inventory create a VAT transaction?

VAT treatment does not depend exclusively on whether a sale has taken place. The physical movement of goods between two EU Member States can itself be relevant.

When a business transfers its own inventory from Bulgaria to another EU country while retaining ownership, the transaction may be treated as a transfer of own goods for VAT purposes. This can result in reporting requirements in the country of departure and corresponding obligations in the country where the goods arrive.

Businesses should therefore remember that:

• a third-party customer does not necessarily need to be involved;
• ownership of the inventory may remain with the same company;
• the absence of payment does not automatically remove VAT obligations;
• the physical location of the products can influence VAT compliance.

Could a foreign warehouse require a local VAT registration?

This is one of the most important questions to assess before introducing a new fulfilment structure.

Imagine that a Bulgarian online retailer previously shipped every order directly from Bulgaria. The company then decides to place its most popular products in a German fulfilment centre. Customers may receive their orders faster, but from a VAT perspective the business now has inventory physically located in Germany.

Depending on the circumstances, this may create local VAT registration and reporting requirements. The Bulgarian VAT number should not automatically be assumed to cover every transaction involving the foreign inventory.

Which documents should support the stock movement?

International fulfilment often involves several systems at the same time: accounting software, an online shop, marketplace reports, warehouse platforms and courier records. VAT compliance becomes more difficult when these systems show different information.

A company should be able to follow the movement of its products from the original warehouse to their destination. Relevant records may include:

• transport and shipping documents;
• warehouse receiving confirmations;
• internal stock transfer records;
• product descriptions, quantities and SKUs;
• dispatch and arrival dates;
• fulfilment-provider inventory reports;
• records of returns, damaged stock and write-offs;
• accounting entries corresponding to the physical stock movements.

The objective is not simply to collect documents. The records should tell a consistent story about where the inventory was located at each stage of the supply chain. ✅

Does OSS cover stock held in another EU country?

The One Stop Shop can simplify VAT reporting for certain cross-border B2C sales, but it should not be treated as a universal solution for every VAT obligation arising from an e-commerce structure.

The sale to the final consumer and the earlier movement of the company’s own inventory are separate parts of the supply chain. A business may therefore use OSS for qualifying sales while still having to consider VAT obligations connected with stock stored in another Member State.

A complete review should consider:

• the original transfer to the foreign warehouse;
• subsequent customer sales;
• customer returns;
• inventory corrections;
• damaged or missing goods;
• transfers between different fulfilment centres.

What will the ViDA reforms change?

The European Union’s VAT in the Digital Age (ViDA) reforms are gradually modernising the European VAT system. One of the important developments for businesses using cross-border warehousing is the Single VAT Registration framework.

From 1 July 2028, the new framework includes a special scheme designed for certain transfers of own goods. The objective is to simplify VAT compliance and reduce the need for multiple local VAT registrations in qualifying situations.

This is an important future development, but businesses should distinguish carefully between upcoming simplifications and the rules that apply today. Existing warehouse structures should continue to be assessed under the current VAT requirements until the relevant new rules become applicable.

What should you check before sending inventory abroad?

Before launching a new warehouse or fulfilment arrangement, it is useful to map the entire movement of the products rather than reviewing only the eventual customer sale.

• Which country will the goods leave from?
• Where will the inventory physically be stored?
• Will the logistics provider move products between different countries?
• Which VAT numbers may need to be used?
• How will transfers be recorded in the accounting system?
• How will returns and stock adjustments be handled?
• Who will reconcile warehouse data with accounting records?

👉 If your business is planning a multi-country warehouse or fulfilment structure, T&G Consulting can assist with reviewing VAT registrations, inventory flows and the accounting framework required for cross-border operations.

Moving own goods between EU warehouses can support faster deliveries and make European expansion more efficient, but inventory and VAT planning should develop together. Businesses that understand where their products are physically located, maintain reliable documentation and review VAT registrations before changing their fulfilment model are better prepared to scale without creating unnecessary compliance gaps. 🙂

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This article provides general information and does not constitute individual tax, accounting or legal advice. The correct treatment depends on the facts and circumstances of each business.

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