EC Sales List for Amazon FBA stock transfers

Yes, you have to report it: moving your own goods from Germany to an Amazon warehouse in another EU country, where they are at your disposal, counts as a supply and belongs in the EC Sales List (ZM), unless the use there is merely temporary or you are a small business (Kleinunternehmer). You file it with the BZSt by the 25th day after the reporting period, stating your own VAT ID in the destination country and the sum of the tax bases.

Last updated: 27 October 2026

In brief

Duty: moving your own goods to another EU country for your own disposal, other than for merely temporary use, goes into the ZM (section 3(1a) and section 18a(6) no. 2 UStG).
Deadline: monthly by the 25th day after the month ends; you may file quarterly if the sum is not more than 50,000 euros in the current quarter or in any of the four previous quarters.
What you state: your VAT ID in the destination country and the sum of the tax bases for it.
If it is wrong: a missing or wrong ZM can cost the supply its tax exemption.

Who has to file the EC Sales List?

Every entrepreneur who has made intra-Community supplies of goods in a calendar month reports them to the BZSt (section 18a(1) UStG). It also counts as a supply for consideration when you move an item of your business, for your own disposal, to the rest of the Community, except for merely temporary use (section 3(1a) UStG). That transfer counts as an intra-Community supply (section 6a(2) UStG), and for the ZM it expressly counts as a supply of goods (section 18a(6) no. 2 UStG).

For you this means: if you send goods to an Amazon warehouse in another EU country and they are at your disposal there, that is a reportable transfer, even if no customer has bought yet. How pan-European storage and the registration abroad fit together is in Amazon pan-European FBA and VAT.

Small businesses (Kleinunternehmer) that apply section 19(1) UStG have no duty to file a ZM (section 18a(4) UStG).

Which VAT ID and which amount do you report?

For a transfer, the ZM states the VAT identification number you hold in the member state to which you moved the goods, and the sum of the tax bases that falls on it (section 18a(7) sentence 1 no. 2 UStG). So it is your own number in the destination country, not a customer's. You get that number when you register there.

For a transfer, the amount is the purchase price of the goods plus incidental costs, or the cost price if there is no purchase price, in each case at the time of the transaction (section 10(4) no. 1 UStG). It is not the later selling price to the customer.

Where do you spot the transfer in the Amazon report?

Amazon describes the VAT Transactions Report (AVTR) as containing, among other things, cross-border inbound shipments and transfers between fulfilment centres. You find it in Seller Central under Reports, Fulfilment by Amazon, Taxes, Amazon VAT Transactions Report. One report may cover at most 93 consecutive days, and the monthly report is available on the third day of the following month according to Amazon, so before the 25th.

The columns DEPARTURE_COUNTRY and ARRIVAL_COUNTRY show the country of departure and arrival of a transaction. For transfers between fulfilment centres, Amazon gives as the date the day the stock was checked in at the receiving fulfilment centre (type FC_TRANSFER). Which row is the transfer in your case depends on the route of your goods; Amazon explains the fields on its help page on the field definitions. More on the columns is in Amazon VAT report columns explained, and on downloading in Download the Amazon VAT report.

By when and how often do you file?

The rule is monthly: by the 25th day after the end of the calendar month (section 18a(1) sentence 1 UStG). You may file quarterly if the sum of the tax bases is not more than 50,000 euros either for the current quarter or for any of the four previous quarters (section 18a(1) sentence 2 UStG). If you exceed the limit during a quarter, you report for the month of the excess and the elapsed months of the quarter by the 25th day after that month (section 18a(1) sentence 3 UStG).

The data belongs in the reporting period in which the invoice is issued, at the latest in the reporting period in which the month following the supply ends (section 18a(8) UStG). Example for a monthly filer: transfer in March, report at the latest for April, filed by 25 May.

A permanent extension of time like the one for the VAT return does not exist for the ZM, says the BZSt.

How do you file it?

The ELSTER portal of the tax administration and the BZStOnline portal (BOP) are available for the ZM. You need a user account for either; if you already have one, you use it for the ZM too. In the BZSt online form you enter the lines by hand or import them from a CSV file, up to 1,500 lines per form.

What if it is wrong or late?

The tax exemption of an intra-Community supply does not apply if you did not file the ZM, or filed it incorrectly or incompletely for that supply (section 4 no. 1 letter b UStG). The BZSt compares the ZM with your VAT returns and sends notification letters if they differ, so that you correct it.

If you notice an error later, you must correct the ZM within one month (section 18a(10) UStG). How a late-filed ZM is treated in your individual case is something your tax adviser can tell you.

Common mistakes

Skipping the ZM because nothing has sold yet. The transfer itself is reportable.
Entering a customer's number. For a transfer you report your own VAT ID in the destination country.
Using the selling price as the amount. Purchase price and incidental costs count.
Counting on an extension. The permanent extension of time does not apply to the ZM.
Leaving a known error. Correct it within one month.

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 the Amazon CSV, and VAT GPT sorts the sales rows by tax scheme and country (Germany or EU/OSS).
With VAT GPT Pro you send the VAT return through ELSTER and the OSS return to the BZSt.

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Frequently asked questions

Do I have to report if the goods are only abroad for a short time? Merely temporary use is excluded from the transfer rule (section 3(1a) UStG). Whether that fits your case is for your tax adviser.

Do I file a ZM as a small business? No, if you apply section 19(1) UStG (section 18a(4) UStG).

Which number goes in the ZM? Your own VAT ID in the country to which you moved the goods.

Does the permanent extension apply to the ZM? No, according to the BZSt it does not apply to the ZM.

How does it differ from the VAT return? The ZM goes to the BZSt and states numbers and sums; the VAT return goes to the tax office and states the tax.