Amazon Pan-EU FBA and VAT: what applies to stock in other EU countries?

Do you sell from Germany through Pan-EU FBA, with stock in several EU countries? Amazon says you need a VAT ID in every storage country. Storing is a transfer, and sales in the storage country belong, says the European Commission, in that country's national VAT return. Only cross-border distance sales to private customers can go into the OSS.

Last updated: 27 October 2026

In short

Amazon: A VAT ID is required for every country where goods are stored; in the destination shop generally not.
Storing abroad: The transfer to another EU country is treated as a supply for consideration (§ 3 (1a) UStG).
Warehouse sales: Nationally in the storage country; to private customers in other EU countries optionally via the OSS.

How does Pan-EU FBA work for tax?

According to Amazon, it stores your products in the EU countries you activate for this and can move your inventory between EU fulfilment centres at its discretion and free of charge. You activate storage for at least two countries. For tax this means that your stock no longer sits only in Germany, and every additional storage country brings its own VAT obligations.

The cases below look at sales to private customers. Sales to business customers with a VAT ID follow other rules and are not covered here.

Step 1: Storing abroad is a transfer

The transfer of an item of the business from the domestic territory to the rest of the Community by a business to have it at its disposal, other than for a merely temporary use, counts as a supply for consideration; the business is treated as the supplier (§ 3 (1a) UStG). A transfer of this kind also counts as an intra-Community supply (§ 6a (2) UStG). You must be able to prove the conditions (§ 6a (3) UStG). The law mirrors the process for goods arriving in Germany: there, a transfer from the rest of the Community counts as an intra-Community acquisition and the business is treated as the acquirer (§ 1a (2) UStG). For the storage country, its own VAT law applies. Amazon asks for the VAT ID there.

In the recapitulative statement (Zusammenfassende Meldung, ZM) you state the transfer with the VAT ID you hold in the member state to which you moved the goods and the total of the taxable amounts (§ 18a (6) no. 2 and (7) no. 2 UStG). The statement is due by the 25th day after the end of each calendar month in which you made intra-Community supplies of goods; under certain amount limits the calendar quarter is enough (§ 18a (1) UStG). You also declare the taxable amount of the transfer separately in your advance VAT return (§ 18b sentence 1 no. 1 UStG). The intra-Community supply is exempt only if you file the ZM correctly and completely (§ 4 no. 1 (b) UStG). Businesses that apply the small business scheme under § 19 (1) UStG are excluded (§ 18a (4) UStG); under § 19 (1) sentence 2 UStG the rules on the exemption of intra-Community supplies do not apply to them.

Step 2: Where do you declare a sale from the warehouse?

Example: you are based in Germany and have stock in a warehouse in Germany and in one in Poland (Amazon names Poland as a Pan-EU storage country). The customers are private individuals.

Sale	Dispatch	Destination	Where you declare it
From the German warehouse to a customer in Germany	Germany	Germany	In your German VAT return
From the German warehouse to a customer in France	Germany	France	Distance sale; possible in the OSS via Germany
From the Polish warehouse to a customer in Poland	Poland	Poland	Domestic supply in Poland; in the Polish VAT return
From the Polish warehouse to a customer in France	Poland	France	Distance sale; possible in the OSS, with the VAT ID of the dispatch country Poland
From the Polish warehouse to a customer in Germany	Poland	Germany	Distance sale into Germany, place of supply Germany (§ 3c (1) UStG); if you use the OSS, you declare it in the OSS with the VAT ID of the dispatch country Poland (UStAE section 3.18 (2) example 4), otherwise in your German advance VAT return
Goods from Germany into the Polish warehouse	Germany	Poland	Transfer: exempt intra-Community supply in Germany (§ 4 no. 1 (b), § 6a (2) UStG); in the advance VAT return (§ 18b UStG) and in the ZM

Step 3: What goes into the OSS?

The EU Commission describes intra-Community distance sales as supplies of goods that the supplier dispatches or transports from one member state to another to private individuals. Any business can declare them in the OSS (Union scheme), even if the goods leave from a member state other than the one where it is established. Supplies from Cyprus to Cyprus and from Bulgaria to Bulgaria, by contrast, are not distance sales and belong in the respective national VAT return (Commission). The OSS returns are additional and do not replace the national return (Commission).

For goods dispatched from a member state other than the member state of identification, the OSS return has its own part (part 2d). There you enter the VAT ID of the member state from which the goods are dispatched. If you have none there and do not have to register there, the country code of that member state is exceptionally enough (Commission). More on the procedure: How to submit an OSS VAT return in Germany: step by step and Amazon OSS VAT: threshold, VAT ID number, reporting.

Does the €10,000 threshold cover every warehouse?

According to the Commission, since 1 July 2021 the €10,000 threshold also covers distance sales whose transport starts in the supplier's member state of establishment. One condition is, among others, that the goods leave from the member state in which you are established. A warehouse in another member state does not meet that condition on its wording. How the threshold works for sellers in Germany is described in EU VAT OSS threshold of 10,000 euros: examples.

How do I register in the storage country?

Amazon asks for the VAT ID for each storage country. How you register there depends on the law of that country; no German law regulates it. Amazon also says you can start with just two VAT IDs without registering in every country where you sell. Whether a local registration or the OSS fits your sales is answered in OSS vs local VAT registration in the EU: which fits when? and by your tax adviser.

Which mistakes happen often?

Declaring only Germany and the OSS. Sales in the storage country to customers in the same country belong in that country's national return.
Overlooking the transfer. Storing abroad is a tax event in Germany (§ 3 (1a) UStG).
Treating the OSS as covering everything. It is for distance sales, not for domestic supplies in the storage country.
Leaving out the dispatch-country entry in the OSS return. For goods from other member states there is part 2d.
Applying the threshold to foreign warehouses. The Commission names it for supplies from the country of establishment.
Forgetting the proof. You must be able to prove the conditions of the intra-Community supply (§ 6a (3) UStG).

How VAT GPT helps

This is how you work with your Pan-EU sales in VAT GPT:

Upload: You upload the Amazon transaction report (AVTR) as CSV; VAT GPT recognises it by the column TAXABLE_JURISDICTION.
Check: VAT GPT sorts the sales: supplies from Germany to Germany into German VAT, cross-border distance sales into the OSS. Sales that Amazon reports as standard taxation (REGULAR) in a country other than Germany are shown separately by VAT GPT as "EU country VAT": the VAT you must report through your own registration in that country.
Send: You send the advance return and the OSS return with VAT GPT Pro via ELSTER.

There is Free (basic features, free of charge), Go (30 days free with all Pro features) and Pro (€49 per month or €444 per year, each including VAT). Sending to ELSTER is part of Pro. Try for Free Now

Frequently asked questions

Do I need a VAT ID in every storage country with Pan-EU FBA? According to Amazon, yes: a VAT ID is required for each country in which goods are stored.

Do I also need a VAT ID in the destination country? According to Amazon, it is generally not required in the destination store.

Is storing goods abroad a supply? The transfer of an item from the domestic territory to the rest of the Community counts as a supply for consideration (§ 3 (1a) UStG), not in the case of merely temporary use.

Can I declare sales in the storage country through the OSS? Sales to customers in the same country as the warehouse are domestic supplies; for them the Commission names the national VAT return.

What belongs in part 2d of the OSS return? Distance sales of goods dispatched from a member state other than the member state of identification, with the VAT ID of the dispatch country (Commission).

Does the OSS return replace my national return? No, it is additional (Commission).