Amazon FBA: VAT, foreign stock and filings in 2026
Storing through Amazon FBA in several EU countries triggers local VAT registrations the OSS does not cover. Distance sales, stock transfers, IOSS, costs and timing: the full 2026 picture.
Expert note: This article was written by our chartered accountancy firm. Information is current as of 2026. For a personalised review of your situation, contact us.
Quick answer. The OSS single window is not enough under pan-EU Amazon FBA. B2C distance sales to the EU fall under the OSS above 10,000 euros per year (a single threshold across all EU countries combined), declared from France. But as soon as Amazon stores your goods in a warehouse abroad, you generally have to register for VAT in that country, apply its local rate (for example 19% in Germany, 22% in Italy, 21% in Spain, against 20% in France) and declare local sales and stock transfers there. The registration should be set up before the stock arrives. It is the most frequent FBA trap.
Selling on Amazon with FBA logistics simplifies shipping, but seriously complicates VAT as soon as stock is spread across several EU countries. Many sellers discover their obligations in the storage countries too late, sometimes through a letter from a foreign tax authority several months after the first local sale. This article walks through the VAT rules of FBA beyond the OSS single window alone, on the often-forgotten side of foreign stock, based on the intra-EU distance-sales regime (French Tax Code, art. 258 A and following). Since the precise rules of each member state must be confirmed locally, this article gives you the reading grid, not a substitute for a country-by-country analysis. For the overview of selling on Amazon, see our guide selling on Amazon France: VAT, margin, FBA.
Distance sales and the OSS single window#
The first regime concerns B2C cross-border sales within the EU.
For intra-EU distance sales to individuals, a single threshold of 10,000 euros per year applies. This threshold is global: it is assessed across all EU countries combined and aggregates all intra-EU distance sales of goods, together with certain cross-border electronic services. Below it, the seller charges French VAT. Above it, they must apply the VAT of the destination country, and can either register in each country or use the OSS single window, which lets them declare and pay this VAT from France, in a single quarterly return. The OSS therefore considerably simplifies the management of cross-border sales: one return replaces several local filings.
But the OSS only solves part of the problem: it covers distance sales, not stock movements, nor local sales made from a foreign warehouse. This is where pan-EU FBA changes matters.
The foreign stock trap#
Pan-EU FBA spreads stock across several countries, which creates its own obligations, distinct from the OSS.
To optimise its deliveries, Amazon distributes the seller's stock in warehouses located in several EU countries, for example Germany, Italy, Spain, Poland or the Czech Republic. Now, the mere fact of storing goods in a country generally triggers a VAT registration obligation there, once a local sale is made, regardless of the distance-sales threshold. Moreover, each transfer of stock from one country to another is generally treated for tax purposes as a deemed operation in the departure country and an intra-EU acquisition in the arrival country, both of which must be tracked and declared. The OSS single window does not cover these stock transfers. The exact rules depend on the law of each member state and must be checked locally.
The pan-EU seller must therefore, in addition to the OSS, register for VAT in each storage country, declare their local operations there and track the intra-EU transfers of their own goods. It is a stacking of obligations, not a choice between OSS and registration.
| Operation | VAT regime | Covered by OSS? |
|---|---|---|
| Intra-EU B2C distance sale (above the 10,000-euro global threshold) | VAT of destination country | Yes |
| Intra-EU B2C distance sale (below the 10,000-euro global threshold) | French VAT | Not applicable |
| Storage in an EU country | Local VAT registration generally required | No |
| Stock transfer between countries | Deemed operation at departure + acquisition at arrival | No |
| Local sale from a foreign warehouse | Local VAT, declared in the country | No |
| Import from outside the EU (consignment not exceeding 150 euros) | Import VAT, IOSS possible | Via IOSS, not the OSS |
When to register: before the stock arrives, not after#
Timing is decisive, because a late registration does not disappear: it has to be caught up.
The principle to remember is that you should register for VAT in a country before storing goods there and making local sales, not once the flow is in place. The triggering event is the presence of stock and the local sale that follows, not a turnover threshold to cross. In practice, Amazon can activate a new storage country very quickly, sometimes within a few days of switching on pan-EU FBA, which leaves little room to obtain a local VAT number before the first operations.
When registration has not been anticipated, it is done retroactively: a VAT number is requested with effect from the actual start date of operations, then the past returns are filed and the VAT due is paid, increased by late-payment interest and, depending on the country, penalties. Retroactive registration is possible in most member states, but it costs more and takes longer than an anticipated registration, because it means reconstructing months of operations from the Amazon reports. Our recommendation is therefore clear: if you know a country will be activated, start the registration upstream; if you discover it has already been activated, handle the regularisation without delay, because late-payment interest accrues every month.
VAT rates and cash flow: a point not to overlook#
Local sales from a foreign warehouse bear the VAT of the storage country, whose rate differs from the French rate.
For guidance, the standard VAT rate is 20% in France, around 19% in Germany, 22% in Italy, 21% in Spain, 23% in Poland and 21% in the Czech Republic (rates to be verified, liable to change). This variation has two concrete effects. First on margin: a local sale in Italy bears higher VAT than in France, which can eat into your margin if your selling prices are aligned on the same gross amount across all countries. Then on cash flow: VAT collected abroad is owed to the local authority, on a calendar specific to each country, while input VAT (purchases, imports) is recovered in the corresponding country of registration, sometimes with a lag. A pan-EU seller therefore manages several VAT flows in parallel, each with its own rate, filing rhythm and refund calendar. Managing VAT cash flow country by country is fully part of the work, on the same footing as the returns themselves.
OSS, IOSS, registration: do not confuse three tools#
Three mechanisms coexist and answer different situations. Confusing them is the most costly mistake.
The OSS (One-Stop-Shop) is for intra-EU distance sales: goods already in the EU shipped to an individual in another member state. The IOSS (Import One-Stop-Shop) is for distance sales of goods imported from a third country, in consignments not exceeding 150 euros: it lets you collect VAT at the point of sale rather than at customs clearance. Local registration, finally, is unavoidable as soon as there is a physical presence of stock in a country: neither the OSS nor the IOSS replaces it. An FBA seller importing from China into a German warehouse potentially combines all three logics. The right to deduct input VAT is then handled in each country of registration, on a logic close to the one set out in our article on the partial taxable person's VAT.
| Criterion | OSS | IOSS | Local registration |
|---|---|---|---|
| Operations covered | Intra-EU B2C distance sales | Distance sales of imported goods (consignment 150 euros max) | Local sales and transfers from stock held in the country |
| Location of goods | Already in the EU | Imported from a third country | Physically stored in the country |
| Filing | One single return from France | One single monthly return | Local returns, in each country |
| Replaces local registration? | No, for storage | No, for storage | Not applicable |
| Typical FBA case | Sale from France to an EU individual | Direct import to an EU customer | Amazon stock in Germany, Italy, etc. |
The cost of multi-country compliance#
Pan-EU VAT compliance carries a recurring cost that should be built into the logistics decision from the start.
The orders of magnitude depend on the number of countries, the provider and the volume of operations, but some markers can be given. VAT registration in a given country involves one-off setup fees, then a recurring filing cost per country and per period. To this may be added, where relevant, the appointment of a fiscal representative (rarely required within the EU for a taxable person established in another member state, but possible outside the EU), the translation of documents and the tracking of stock transfers. In practice, each additional storage country adds a fixed annual cost line, regardless of the turnover achieved there. This is precisely why activating pan-EU FBA deserves a trade-off: multiplying storage countries only makes sense if the logistics and commercial gain exceeds the combined cost of registrations and filings. We cost this trade-off case by case, as the break-even point depends on margin, volume and the number of activated countries.
Micro-entrepreneur status and FBA abroad#
Pan-EU FBA interacts with micro-entrepreneur status in a way that is often overlooked.
The micro-entrepreneur regime, and more broadly the French VAT base exemption, is a national regime: it does not travel. As soon as a seller registers for VAT in another country because they store goods there, they become an ordinary taxable person for VAT in that country: they collect the local VAT, file returns and do not benefit from the French exemption beyond the border. In other words, storage abroad takes the seller out of the filing comfort of the micro regime for the local operations concerned, country by country. In France, the micro regime and the base exemption remain assessed under their own rules and thresholds, to be confirmed for your situation. The operational consequence is that a micro-entrepreneur who activates pan-EU FBA must anticipate managing real VAT abroad, even if they remain exempt for their French sales. This point sometimes changes the trade-off: for a seller keen to keep the micro regime, limiting storage to France is often more consistent.
Limiting FBA to a single country in Seller Central#
The number of storage countries is controlled in the Amazon account, not left to default.
In Seller Central, the setting for the pan-EU programme and the storage countries is found in the FBA logistics settings. The exact path changes with interface versions, but it runs through the account Settings, the Fulfilment by Amazon (FBA) section, then the Pan-European FBA or cross-border inventory area, where storage is enabled or disabled by country. Check this setting regularly: Amazon may offer or activate new countries over time, and this is what surprises sellers the most. As long as the pan-EU programme is limited to a single country, you avoid multiple registrations; as soon as you widen it, you take on the obligations described above. Treat this setting as a tax decision, not only a logistics one.
The filings not to forget#
Pan-EU FBA multiplies the filing obligations, in several languages and on several calendars.
Beyond the quarterly OSS return for distance sales, the seller must file periodic VAT returns in each country where they are registered, keep a register of stock movements, and prepare the statistical and tax statements linked to intra-EU movements of goods (in France, the statistical survey on movements of goods and the EU sales list, with their local equivalents abroad). The complexity increases with the number of storage countries, and each country has its own filing rhythm and deadlines. An error or oversight exposes the seller to VAT back-payments and penalties in several countries at once, with accumulated late-payment interest.
Our view#
FBA is a tremendous logistics tool, but its VAT side is underestimated by most sellers. The most frequent confusion we see in practice is believing the OSS single window solves everything: it covers distance sales, not storage in several countries, which is precisely what pan-EU FBA does. We regularly see sellers perfectly up to date with their OSS, but in silent breach in two or three storage countries Amazon activated without their grasping the consequences.
Our approach is to first map the storage countries activated in the Amazon account (inventory and fulfillment reports), to anticipate the corresponding VAT registrations, then to set up the tracking of stock transfers before they pile up. For a seller starting out, switching off multi-country storage and limiting FBA to a single country avoids this complexity; for a seller already pan-EU, multiple registration and rigorous tracking are unavoidable. It is better to anticipate these obligations than to discover them during an audit in a foreign country, where you control neither the language, nor the procedure, nor the limitation periods. This tracking belongs to a full business taxation engagement, not to a simple French return.
A common case: a seller up to date on OSS, in breach on storage#
A French seller had activated pan-EU FBA to speed up deliveries, without gauging the VAT consequences. Amazon spread their stock across three additional countries, triggering registration obligations they were unaware of. They filed scrupulously via the OSS and paid their French VAT, convinced they were compliant. The analysis of their Amazon reports revealed that they should have registered for VAT in each storage country and tracked their local operations and stock transfers there, in some cases for over a year. The regularisation required retroactive registrations, the filing of past returns and the payment of late-payment interest in each country. Thereafter, the storage countries were framed and the registrations set up upstream, before any activation by Amazon.
In practice: securing your FBA VAT#
Here is the operational sequence we follow for a pan-EU FBA seller.
- Map the countries where Amazon spreads your stock, from the inventory and fulfillment reports in Seller Central.
- Register for VAT in each storage country before the stock arrives, without waiting for a possible distance-sales threshold.
- Activate the OSS single window for distance sales above the 10,000-euro global threshold, and the IOSS if you import goods in consignments not exceeding 150 euros.
- Apply the VAT rate of the storage country to local sales, and manage VAT cash flow country by country.
- Track and declare each stock transfer between countries, as a deemed operation at departure and an acquisition at arrival.
- Keep a register of stock movements and respect the filing calendar specific to each country.
- Reconcile the Amazon reports with the returns filed every quarter, to detect any newly activated country.
Watch points#
A few pitfalls keep coming up in FBA sellers' files, especially during rapid growth.
- Believing the OSS removes the need for local registration: it covers neither storage, nor local sales from a foreign warehouse.
- Forgetting that the 10,000-euro threshold is a single global threshold, assessed across all EU countries combined, not country by country.
- Assuming that goods stored but not yet sold carry no consequence: storage already creates a presence, and the registration obligation crystallises with the first local sale made from that warehouse, including where part of the stock is later withdrawn or transferred without ever being sold.
- Overlooking stock transfers initiated by Amazon, which happen without seller action but still must be tracked and declared.
- Confusing OSS and IOSS: the IOSS targets imports in consignments not exceeding 150 euros, not intra-EU sales.
- Underestimating the risk of double assessment: a mishandled operation can be reassessed in two countries at once.
- Activating pan-EU FBA by default without setting the authorised countries, when this setting is controlled in the Amazon account.
Frequently asked questions
Is the OSS single window enough for Amazon FBA?+
No. The OSS covers intra-EU B2C distance sales, but not the storage of goods in several countries, specific to pan-EU FBA, nor local sales made from a foreign warehouse. Storing abroad generally requires VAT registration in each country concerned, on top of the OSS.
Should you register before or after the stock arrives?+
In principle before. The obligation arises from the presence of stock and the local sale that follows, not from a turnover threshold. The ideal is therefore to obtain the local VAT number before Amazon activates the country. Where that is not done in time, retroactive registration remains possible in most member states, but it means filing the past returns and paying late-payment interest, and possibly penalties.
What is the distance-sales threshold?+
A single threshold of 10,000 euros per year, assessed globally for all intra-EU B2C distance sales, across all EU countries combined (and including certain cross-border electronic services). Below it, the seller charges French VAT; above it, the VAT of the destination country, declared via the OSS or by local registration.
Does micro-entrepreneur status survive storage abroad?+
The micro regime and the base exemption are French regimes: they do not apply outside France. As soon as a seller registers for VAT in a storage country, they become an ordinary taxable person there, collect the local VAT and file returns in that country. They may remain exempt for their French sales, but they manage real VAT abroad. For a seller attached to the micro regime, limiting storage to France is often more consistent.
What does multi-country compliance cost?+
It depends on the number of countries, the provider and the volume, but each storage country adds a fixed cost: one-off registration fees, then recurring filing work, to which a possible fiscal representation and document translation may be added. That is why activating pan-EU FBA deserves a costed trade-off: multiplying countries only makes sense if the logistics gain exceeds the combined cost of registrations and filings.
How do you limit this complexity when starting out?+
By setting FBA to a single storage country in the Amazon account, through the FBA logistics and pan-EU network settings, which avoids multiple registrations and transfer tracking. Pan-EU FBA, more efficient logistically, is only justified with rigorous VAT tracking in each country. For a group structure or a reflection on where to establish, this choice connects to a broader analysis, for example of holding structuring.
Key takeaways#
- For Amazon FBA, distance sales (OSS) and foreign storage fall under distinct VAT regimes that overlap.
- Intra-EU B2C distance sales above the 10,000-euro global threshold fall under the OSS single window, declared from France.
- Storage in an EU country generally requires VAT registration there, before the stock arrives, regardless of the distance-sales threshold.
- Local sales bear the VAT rate of the storage country, which differs from the French rate and weighs on margin and cash flow.
- Stock transfers between countries are tracked as a deemed operation at departure and an acquisition at arrival, outside the OSS.
- The IOSS concerns imports in consignments not exceeding 150 euros, not to be confused with the OSS.
- Anticipating the storage countries, the registrations and their cost avoids back-payments and penalties in several countries at once.
Article written by the Hayot Expertise firm, registered with the Order of Chartered Accountants of Ile-de-France. Updated for 2026. This article is for information purposes and does not replace an analysis of your own situation, which requires a review of your Amazon reports, your flows and the rules in force in each country concerned. The foreign VAT rates cited are indicative and must be verified at the date of the operation.

Article written by Samuel HAYOT
Chartered Accountant, registered with the Institute of Chartered Accountants. Certified Pennylane trainer.
Regulated French accounting and audit firm based in Paris 8, built to support companies across France with a digital and decision-oriented approach.
Sources
Official and operational sources cited for this page.
- impots.gouv.fr - J'utilise le guichet unique TVA (IOSS-OSS)
- Legifrance - CGI, art. 258 A (ventes à distance intracommunautaires de biens)
- economie.gouv.fr (CEDEF) - Comment fonctionne la TVA pour la vente en ligne
- bofip.impots.gouv.fr - TVA, ventes à distance de biens (commerce électronique)
- Commission européenne - Taux de TVA appliqués dans les États membres
This topic is part of our service Tax accountant in Paris | CIT, VAT & tax audits
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