If Amazon Collects VAT, Do You Need VAT Registration?

Under Article 14a of the VAT Directive, a qualifying electronic interface is the deemed supplier for two sets of sales: imported consignments up to EUR 150, and goods already in the EU sold by a seller not established in the Union. For those sales the platform charges and remits the customer VAT, and your own supply to the platform is exempt with a right of deduction. The mechanism is set out in our guide to the EU deemed supplier rule.

That is the whole of what moves. It is a rule about who accounts for the VAT on a specific sale, and the Commission is explicit that it is a fiction for VAT purposes: the platform generally never possesses the goods, and ownership still passes from you to the buyer. Nothing in it addresses how the goods got into the EU, where they are sitting, or what happened to them between arrival and sale.

So the honest answer to the question in the title is that the two things are unrelated. You can have almost no VAT of your own to declare on marketplace sales and still owe several registrations, several nil or near-nil returns, and in some countries a fiscal representative.

The main triggers sit outside the marketplace sale. Importation can require the importer of record to deal with import VAT in the Member State of entry. A transfer of your own goods across an internal EU border creates a deemed supply on departure and a deemed acquisition on arrival. Passive storage after arrival is not another taxable transaction, although the earlier import or transfer, later local supplies, input VAT and reporting requirements commonly make the local registration necessary.

Article 17(1) of the VAT Directive treats a transfer of your own business goods to another Member State as a supply of goods for consideration in the country of departure. Article 21 treats the arrival as an intra-Community acquisition. An acquisition is a taxable transaction, and Article 214 requires the person making it to be identified for VAT in that country. You have therefore made a taxable transaction in a country where you have never sold anything.

The practical consequence is that the registration question has to be answered before the first sale, not after it. A seller who waits for revenue in a country to justify registering has usually already created the obligation on the day the pallet arrived.

The reason this catches sellers out is that the movement is often not their decision. A pan-European or multi-country fulfilment programme redistributes inventory to wherever the operator expects demand. Each of those movements is a transfer of your own goods, made in your name, and each one lands in a country where you may have no sales, no local presence and no registration.

This is a settings question as much as a tax question. Where a programme lets you choose the storage countries, that choice is the registration footprint. Turning a country on is a decision to register there, and turning one off does not retroactively remove an obligation already created.

Because the warehouse decision creates the tax position, it should be flagged upstream. We work with 3PL and logistics providers so that a new storage country is raised as a registration question before the pallets move rather than after a tax office letter.

Before any of the storage analysis, settle who imports. The importer of record is liable for the import VAT and, where it has the right to deduct, is the party that can recover it. Getting this wrong is the most expensive error in the whole chain, because import VAT paid by a party with no right of deduction is simply a cost.

It also needs an EORI number, which is a customs identifier and not a VAT number. A business can hold a valid VAT registration in a country and still be unable to clear its own goods there. Our EORI registration service covers that side, and the customs rules that changed in July 2026 are in the EU customs duty on low-value parcels.

Where a freight forwarder or a carrier offers to import in its own name, read what that does to the deduction. The party that owns the goods and later sells them is usually the one that should be importing them.

EU VAT sets the mechanics, not every national consequence. Registration procedures, filing frequencies, local listings, refund routes and fiscal representation requirements still differ from one Member State to the next, and a seller with the same flow in five countries can face five different administrative positions.

France is a good illustration. A non-EU seller storing goods in France needs a French VAT number, and depending on where the business is genuinely established it may also need an accredited representative rather than a simple registration. Our French VAT registration for marketplace sellers and fiscal representation for non-EU sellers pages set out that route. Which countries require a representative is itself a country-by-country question, covered for France in our note on the exempt countries.

Once registered, the returns still have to be filed even when the marketplace collected the VAT. Deemed supplier sales are not invisible: they appear in your accounts as exempt supplies, and the local return has to reflect that rather than show nothing at all. That is the work our VAT returns service handles.

Council Directive (EU) 2025/516 introduces a special scheme for transfers of own goods from 1 July 2028. For transfers inside the scheme, the intra-Community acquisition in the destination Member State is exempt and, notwithstanding Article 214(1), expressly does not create a registration obligation there. For a multi-country FBA seller, that removes the single largest cause of extra registrations.

It is not a clean sweep, and the conditions matter. The scheme is optional but applies to all covered transfers once chosen. It does not cover transfers where there is no full right of deduction in the destination country. Input VAT in the departure and arrival countries is recovered through the refund directives rather than through the scheme return. Any registration required by another activity, such as local B2B sales or an import, survives untouched. The call-off stock simplification in Article 17a closes to new movements after 30 June 2028 and ends entirely on 30 June 2029.

The useful preparation is to record, for each existing registration, the transaction that actually requires it. Registrations caused only by stock movements are candidates for closure in 2028. Registrations caused by imports, local sales or refund positions are not. Doing that inventory now turns 2028 into a deregistration exercise rather than a research project.

The questions below are the ones that decide the answer. Send them to us with your flows and we will tell you which registrations are genuinely required, which are caused only by stock movement, and what changes for you in 2028.

Contact our VAT team with the detail, or start with the country pricing on our pricing page if you want the cost picture first.