Moving from self-fulfilled orders to FBA: what should you check about VAT?
Compare your planned stock route with your existing VAT arrangements before changing fulfilment.
Source checked:
Does this affect my business?
International sellers considering German Amazon FBM-to-FBA or changed EU stock arrangements. UK stock needs a separate review.
What do we know?
Changing who fulfils your orders is a useful point to review your VAT arrangements. First describe what will actually change: the legal seller, where the goods are stored, where orders leave from and who buys them. A German Amazon listing alone does not describe that whole route.
Confirm where Amazon may store your stock before changing fulfilment. Check the current programme and placement countries enabled for your account, then compare them with your existing VAT arrangements. Some Amazon marketing pages still describe its former Call-Off Stock (COS) programme. Amazon announced that this programme ended on 1 August 2024, so do not treat that older comparison as a current route to avoiding local VAT registration. Ask your adviser to assess the actual stock movements and transactions under your current arrangement. Amazon staff: COS programme ended
Review what you already have. Make a country-by-country list of VAT registrations and the written work your adviser covers. Ask whether the planned stock movements, sales and start date fit that scope. This is a check of your arrangements, not an instruction to replace a provider. If the facts and existing coverage already fit, you may need a confirmed reporting process rather than another registration.
Keep national VAT, OSS and IOSS separate. OSS does not replace domestic VAT returns. Goods already held in an EU warehouse are outside the Commission's definition of distance sales of imported goods. An existing IOSS arrangement therefore should not be assumed to cover subsequent sales from EU-held stock. Union OSS covers eligible transactions; it is not a label for every transaction made through an Amazon account. Commission: OSS scope and domestic returns, scheme eligibility
Before changing the fulfilment setup, complete this check:
| What to confirm | What to collect | What to ask your current adviser |
|---|---|---|
| Same legal seller? | Entity and establishment details; changes since registration | Do these registrations and authorisations still belong to this seller? |
| Where is stock now, and where may it be held next? | Current location, permitted placement countries and chosen programme; actual movement reports if stock has moved | Which movements or local transactions need separate treatment under this specific arrangement? |
| How will goods enter and leave those locations? | Planned shipping route, importer and available import／stock documents | Who keeps and reports each record? What is missing? |
| Which sales channels and customers are involved? | Marketplace versus direct sales; business versus consumer sales | Which transactions are handled by the platform and which remain ours? |
| What is already included? | Current engagement, filing countries, latest returns and outstanding notices | Does the current scope cover the change? What extra work, if any, is needed? |
| When does the change start? | Intended first stock movement and order dates | What must be resolved before that date, and what can remain with the current process? |
Treat UK stock as a separate review. For an overseas seller, HMRC distinguishes direct sales of UK-held goods from qualifying marketplace sales. In the marketplace case, accounting for sales VAT does not simply erase import responsibilities. HMRC also describes a registration-exemption option for sellers making only zero-rated deemed supplies; it is not an automatic exemption for everyone using FBA. Northern Ireland has distinct conditions. HMRC: marketplace sales, HMRC: direct sales
Your next step is to send the completed route and coverage table to your existing adviser. Ask for a written list of what is already covered, what needs changing and who will do it. If you ask OCW, start with the stock countries, chosen programme, existing registrations and the point you cannot resolve. Do not post tax identifiers or private documents in an initial public question. A personal registration, exemption or historic correction needs the relevant facts and individual review.
Sources checked 22 October 2026. This page is a review checklist; it does not determine an individual tax position.
Sources and review date
Official source — S1 | Amazon staff Sunnie_Amazon: Amazon COS programme termination notice
Official source — S2 | European Commission: The One Stop Shop, scope and domestic returns
Official source — S3 | European Commission: Register to OSS, scheme eligibility
Official source — S4 | HMRC: Overseas goods sold to UK customers using online marketplaces
Official source — S5 | HMRC: Overseas goods sold directly to customers in the UK
Official source — S6 | Amazon: FBA international, storage and separate UK review
Six approved official sources and review boundaries appear in the full article. Source check: 22 October 2026.
Source checked:
Reading version
vat-fbm-to-fba / ocw-vat-fbm-fba-20261022-reviewed1
Ask about this
I sell on Amazon Germany using FBM and want to start FBA. What should I check about my existing VAT arrangements?
You can edit the suggested question in Chat.
Ask about this →