Storing Goods in the EU? You May Need Another VAT Registration
Expanding into a second EU warehouse can improve delivery times, reduce fulfilment delays and bring stock closer to customers. It can also create a VAT obligation that many businesses do not expect.
A Bulgarian VAT number does not automatically cover stock held across the European Union. When goods move from Bulgaria to a warehouse in Germany, Poland, the Netherlands or another Member State, the VAT analysis may start with that movement rather than with the first customer sale. 📦
This distinction matters for e-commerce businesses, wholesalers and companies using Amazon FBA or other fulfilment networks. To understand the VAT position, you need to know where the goods are physically located at every stage.
Why Moving Your Own Stock Matters for VAT?
Consider a Bulgarian retailer that holds inventory in Sofia. The company sends part of that inventory to its own fulfilment stock in Germany. It retains ownership throughout the journey and has not sold anything to a customer yet.
Commercially, this looks like an internal logistics movement. For VAT, however, transfers of a business’s own goods between EU Member States can fall within the intra-Community VAT framework.
Under the general rules, the business may need to report a deemed intra-Community supply in the country of departure and a corresponding intra-Community acquisition in the country where the stock arrives.
This means that the arrival of stock in another Member State can create local VAT identification and reporting questions before any customer purchases the goods.
The practical lesson is simple: do not wait for the first sale before reviewing VAT.
The Next Sale Depends on Where the Goods Start
Once stock sits in a foreign warehouse, the next transaction needs a fresh VAT analysis. The customer’s location matters, but so does the location of the goods when dispatch begins.
| Scenario | VAT Issue | What to Review |
|---|---|---|
| Stock moves from Bulgaria to Germany | Transfer of own goods | German VAT identification and reporting position |
| German stock is sold to a German customer | Domestic supply | Customer status and German VAT rules |
| German stock is shipped to a French consumer | Intra-Community distance sale | Whether Union OSS can report the French VAT |
| Stock moves to another EU fulfilment centre | Another own-goods transfer | VAT position in the new destination country |
This is why an invoice alone does not tell the full VAT story. Two identical products sold by the same Bulgarian business may receive different VAT treatment because one ships from Bulgaria while the other starts its journey from stock in Germany.
OSS Can Simplify Sales, but Not Every Stock Movement
The Union One Stop Shop can simplify VAT reporting for qualifying cross-border B2C sales within the EU.
If a product stored in Germany is dispatched to a private consumer in France, for example, the transaction may qualify as an intra-Community distance sale. Subject to the applicable conditions, the supplier can report the French VAT through Union OSS instead of obtaining a French registration solely because of that distance sale.
However, this does not mean that OSS solves the earlier movement of the company’s own stock into Germany.
Under the framework applicable in 2026, the transfer of stock and the later B2C sale are separate VAT questions. A business may therefore use OSS for qualifying customer sales while still maintaining a VAT registration in the country where its warehouse stock is held.
Amazon FBA Can Move the VAT Question Without Moving Your Company
Fulfilment networks deserve special attention because the marketplace may have operational control over where inventory is stored.
A Bulgarian business can remain legally established in Bulgaria while its stock moves through several European warehouses. The fact that a marketplace manages that movement does not make the movement irrelevant for the seller’s VAT analysis.
Before activating cross-border fulfilment, identify:
- every country that may hold your inventory;
- the origin and destination of each stock movement;
- whether the provider can transfer inventory automatically;
- the local VAT numbers you already hold;
- which sales belong in domestic VAT returns;
- which qualifying sales you intend to report through OSS;
- how marketplace reports feed into your accounting records.
Do not rely only on monthly sales totals. Warehouse and inventory reports can be just as important because they show when goods changed country before a customer order occurred.
Call-Off Stock Works Only for a Specific Arrangement
EU VAT law contains a call-off stock simplification, but it does not apply to every warehouse.
The arrangement generally concerns goods moved to another Member State for a specific VAT-identified customer who is already known when the transport begins and is expected to take ownership later.
That is very different from sending inventory to a general fulfilment warehouse and waiting for unknown customers to place orders.
The simplification requires several conditions, including customer identification, specific records and reporting. It also operates within a time limit. If the arrangement stops meeting the required conditions, the standard rules for transfers of own goods can become relevant.
For this reason, do not describe an ordinary e-commerce warehouse as “call-off stock” simply because goods wait there before sale.
Map the Stock Flow Before You Sign the Warehouse Contract
A practical VAT review starts with the goods themselves.
- Who owns the inventory during transport?
- Where does the shipment begin?
- Where does it physically arrive?
- How long will the stock remain there?
- Is a specific future buyer already known?
- Will customers be businesses or consumers?
- From which warehouse will customer orders leave?
These questions often reveal the VAT problem before an invoice exists.
Waiting several months can make the review far more difficult. The business may need to reconstruct historical warehouse movements, marketplace reports and invoices to determine when a registration or reporting obligation first arose.
ViDA Changes the Picture From July 2028
Businesses planning long-term European warehouse structures should also consider the EU VAT in the Digital Age reforms.
From 1 July 2028, the main Single VAT Registration measures are scheduled to apply. The reform includes a new special scheme for transfers of own goods, designed to reduce some of the situations in which businesses need separate VAT registrations simply because stock moves between Member States.
That future simplification should not be applied to movements made under the rules in force in 2026. Review each transfer under the law applicable when the movement occurs.
Review VAT Before the First Pallet Leaves Bulgaria
A European warehouse can be a strong commercial decision. VAT should form part of the logistics plan rather than become an accounting problem discovered later. ✅
Planning an EU warehouse, Amazon FBA setup or cross-border fulfilment structure? T&G Consulting can review your stock flows, local VAT registration exposure and OSS reporting before you launch the new arrangement.
The key question is not simply where your company is registered. You also need to know where the stock is located, how it arrived there and where it travels when the customer buys it. Mapping those movements early makes VAT compliance much easier to manage.
For useful and interesting information, visit our partners’ channel.
This article provides general information and does not constitute individual tax, accounting or legal advice. VAT treatment depends on the specific transactions, countries involved and legislation applicable when each movement takes place.