Amazon FBA removals and disposals: the tax side

You have stock sent back from the Amazon warehouse to you, or disposed of? A supply requires that someone else obtains the power of disposal over the goods (section 3(1) UStG); if the stock is sent to yourself, that is no sale. If it comes back from a warehouse in another EU country, section 1a(2) UStG applies to the transfer.

Last updated: 27 October 2026

In brief

Return to you: No sale while no one else can dispose of the goods in their own name.
Back from another EU country: The transfer of your own goods to Germany is covered by section 1a(2) UStG.
Disposal: If you give goods to someone, section 3(1b) UStG can apply; goods that are destroyed and reach no one have no recipient.

What do removal and disposal mean?

With a removal you have stored goods sent from the Amazon fulfilment centre back to you. With a disposal you instruct Amazon to dispose of them; whether the goods are destroyed or passed to someone decides the tax result (see below). On its Fulfilment by Amazon page, Amazon writes (in German) that it takes care of unsold inventory if you choose to have it disposed of. The disposal is your choice.

In the Amazon VAT Transactions Report (AVTR) Amazon lists, among the transaction types, transfers between fulfilment centres, commingling transactions, liquidations and donations. Those are separate events; if someone resells your goods, that is a different question from the return.

Return to you: why it is no sale

The law says that supplies by a trader are services by which the trader, or a third party on the trader's behalf, enables the customer, or a third party on the customer's behalf, to dispose of an object in their own name (transfer of the power of disposal, section 3(1) UStG).

An example: you have 20 units sent back to your warehouse in Germany. Before, you could dispose of the goods; afterwards, you still can. No customer who can dispose of them in their own name appears, so the supply is missing.

Back from a warehouse in another EU country

If you store goods in another EU country (see Amazon Pan-EU FBA and VAT) and have them sent back to Germany, that is a transfer of your own goods. The law treats it as an intra-Community acquisition: the transfer of an item of the business from the rest of the Community into Germany by a trader for their own disposal counts as an acquisition for consideration (section 1a(2) UStG). Temporary use is excluded.

The opposite direction, a transfer from Germany to another EU country, is in section 3(1a) UStG. The rules of the country the goods come back from apply there and are a separate question. Reporting of transfers from Germany to another EU country is covered in Amazon FBA stock transfers and the EC Sales List.

Disposal and donated goods

The law treats as a supply for consideration: any other gift of an item free of charge, except gifts of low value and samples for business purposes. The condition is that the item or its components gave the right to full or partial input VAT deduction (section 3(1b) UStG).

The decree requires for a gift that the giver purposefully procures a financial advantage for the recipient (section 3.3(10) UStAE). If goods are destroyed and no one receives them, there is no recipient to whom this rule refers. If you give goods to someone, for example as a donation, the rule needs to be checked. A gift counts as being of low value if the acquisition or production costs of the items given to the recipient in the calendar year total no more than 50 euros net of VAT (section 3.3(11) UStAE, handbook 2024). This is the rule, not advice for your case.

The fees for removal and disposal

Fees for removal and disposal are business expenses if they are caused by the business (section 4(4) EStG). If the invoice shows German VAT, you deduct it as input VAT if the conditions of section 15(1) sentence 1 no. 1 UStG are met. One of them: exercising the deduction requires that you hold an invoice issued under sections 14 and 14a UStG. If a trader from another EU country invoices without VAT, you owe the tax under section 13b UStG and deduct it under section 15(1) sentence 1 no. 4 UStG. Neither applies to the extent you use the service for tax-exempt supplies, for example as a small business (section 19(1), section 15(2) sentence 1 no. 1 UStG). How this looks with Amazon invoices is shown in Deduct Amazon fees: expenses and input VAT. Amazon sets the amount of the fees; this article gives no figures.

Common mistakes

Booking the return as a sale to yourself. Without a customer there is no supply.
Overlooking the return from another EU country. The transfer to Germany has its own rules (section 1a(2) UStG).
Treating disposal and donation alike. The rule in section 3(1b) UStG requires a gift to a recipient.
Deducting fee VAT without checking the invoice. If it shows German VAT, deduction requires an invoice under sections 14 and 14a UStG; if it shows none, check section 13b UStG.

How VAT GPT helps

VAT GPT is the tax software for Amazon and eBay sellers in Germany: your OSS return first, then every other tax you owe, calculated and filed in one place.

You upload your Amazon and eBay CSV reports, and VAT GPT breaks the VAT down for Germany and the EU (OSS).
From the figures, VAT GPT prepares the VAT return (monthly or quarterly).
You prepare the income surplus statement (EÜR) in the same account.

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Frequently asked questions

Is a removal a sale? No, while no one else can dispose of the goods in their own name (section 3(1) UStG).

What applies if the goods come back from a warehouse in another EU country? The transfer of your own goods to Germany is covered by section 1a(2) UStG.

Do I owe VAT on destroyed goods? The rule in section 3(1b) no. 3 UStG requires a gift to a recipient. Whether it applies in your case, clarify with your tax adviser.

Can I deduct the fees? As business expenses if caused by the business (section 4(4) EStG); the VAT as input VAT if the conditions of section 15(1) sentence 1 no. 1 UStG are met, or under section 15(1) sentence 1 no. 4 UStG for an invoice without VAT from another EU country.

Is a donation the same as a disposal? No, with a donation a recipient receives the goods.