EU VAT for Amazon FBA: EFN, Pan-EU and OSS Explained

✨ Written with AI assistance from European Commission, German and Amazon published rules, and reviewed by Avanta Global EOOD before publication. Learn more

Short answer: in the EU, the country where your stock sits is normally one you must register in. A sale from stock to a buyer in the same country is a domestic sale, and the One-Stop Shop (OSS) does not cover it. A sale to a buyer in another EU country is taxed where the buyer is; OSS reports those from one country. The €10,000 threshold that keeps small sellers on home-country VAT only applies to goods shipped from the country you are established in, so it rarely helps an FBA seller. EFN keeps you to one stock country. Pan-EU adds one per storage country.

We have not sold in the EU yet; our only live store is Amazon Australia. Everything below is quoted from official pages read on 30 September 2026. We are not accountants or tax advisers; check your own case with one.

The rules that decide it

1. Distance sales are taxed where the buyer is. The European Commission: "The place of supply of intra-Community distance sales of goods is in the Member State in which the dispatch/transport of the goods ends."
2. The €10,000 threshold is narrow. Up to €10,000 a year of cross-border consumer sales can stay on home-country VAT, but only if the seller is established in one Member State and the goods are sent from it. The Commission's own Q&A: for a French business that also ships from a stock in Germany, the threshold "is not applicable", because "goods must be sent from that Member State of establishment". Businesses established outside the EU cannot use it at all.
3. OSS does not cover domestic sales. The Commission's example: sales "from Bulgaria to Bulgaria have to be declared in the respective domestic VAT return … because these are not intra-Community distance sales of goods." And for an EU business holding stock in Germany: "you will normally be required to register for VAT purposes in Germany."
4. Moving your own stock across a border is itself taxable. German law treats sending your goods from Germany to another EU country as a supply (§ 3(1a) UStG, temporary use aside), and bringing them into Germany as an intra-Community acquisition (§ 1a(2) UStG). Amazon's German tax page says Amazon moving your FBA stock between countries can count too.

Stock location × buyer: what each setup triggers

For a seller established in one EU country (we are in Bulgaria), selling to consumers. Business sales follow other rules.

Stock sits in	Buyer in	What it is	What you need	Source
Your home country	Your home country	Domestic sale	Home VAT return	EC OSS, example
Your home country	Another EU country	Distance sale	≤ €10,000/yr total: home VAT. Above: buyer's VAT, via OSS at home or a local registration	EC OSS; EC Q&A 1, 2
Another EU country (e.g. DE)	That country	Domestic sale there	Register there; not OSS	EC OSS example; EC Q&A 19
Another EU country (e.g. DE)	A third EU country (EFN)	Distance sale, no threshold	Buyer's VAT from the first euro; OSS at home, or register in the buyer's country	EC Q&A 4, 15, 19
Moved from home to the FBA country	(the move itself)	Transfer of own goods	A supply where it leaves, an acquisition where it arrives	§ 3(1a), § 1a(2) UStG
Outside the EU, shipped into an FC	(the import)	Import	Import VAT and duty; IOSS does not apply	EC OSS; Amazon DE tax page

• EFN from one country: rows 3 and 4 once, plus row 5 or 6 to get the stock there. Amazon: a VAT number "is generally not required in the destination store." Destination VAT still applies; OSS pays it without a local registration.
• Pan-EU: rows 3, 4 and 5 for every storage country. Amazon: a VAT number "is required for each country in which goods are stored", from a minimum of two.
• Central Europe Programme: German stock may sit in Poland or the Czech Republic, which Amazon says "will trigger VAT obligations and other reporting requirements" there.

Registrations against fee savings: Pan-EU vs EFN, the break-even. The fees: Amazon FBA fees in Europe.

If you are established outside the EU

Two things change, per the Commission's e-commerce explanatory notes:

• Amazon becomes the "deemed supplier". Under Article 14a(2) of the VAT Directive, a marketplace that facilitates a sale of goods located in the EU by a seller "not established" in the EU to a consumer is treated as having bought and resold them. Amazon then accounts for the VAT on the consumer sale; your deemed sale to Amazon is "exempt from VAT with the right of deduction."
• You still register where the stock is. The Commission's answer for a non-EU seller with stock in France selling only through marketplaces: "You need to register for VAT purposes in France where you have your stock of goods."

For EU-established sellers like us, Amazon is not the deemed supplier; the VAT on each sale stays ours.

IOSS is for consignments up to €150 sent from outside the EU direct to a buyer. It does not fit FBA: "Goods already stored in a warehouse in the EU are not covered."

Where we stand

Avanta Global EOOD is Bulgarian. Germany assigns foreign traders a tax office by country: for Bulgaria, Finanzamt Neuwied (§ 1 UStZustV). On 9 September 2026 we filed the German registration questionnaire through ELSTER, before shipping any stock. The expected wait is 4–12 weeks. We still owe a certificate of residence from the Bulgarian revenue agency.

Two notes from filing. The light ELSTER account we used (ElsterLight) could submit the questionnaire but, as far as we have found, cannot file returns. And German law requires an advance return for every period (§ 18(1) UStG), monthly in the year a business starts and the year after (§ 18(2)). As we read it, that holds even in a month with no sales.

What we got wrong

We waited on the wrong door. From May to September 2026 our internal notes treated German VAT as pending on an Amazon support thread. Amazon's own German tax page says the application goes to the German tax authority. That wait cost us four months before we filed with the Finanzamt directly.

Amazon's page is out of date. It still lists a €100,000 German distance-selling threshold. The Commission: from 1 July 2021 the old €35,000-per-country threshold "(or EUR 100 000 for a limited number of Member States) disappears", replaced by one EU-wide €10,000. Check thresholds at the source.

The earlier version of this article invented its numbers, including an "analysis of 21 top-selling products" we never did.

How to check your own position

1. List every country where Amazon may hold your stock (home, CEP, Pan-EU).
2. For each one, find the local registration rule. For Germany, § 1 UStZustV names your tax office.
3. If you ship from anywhere but your country of establishment, the €10,000 threshold is gone.
4. Choose OSS (in your home country, if EU-established) or local registrations for cross-border sales.
5. Model the VAT in your margins with our EU FBA profit calculator, then check real charges in your settlement report.

FAQ

Does OSS replace a German VAT number if my stock is in Germany? No. Sales from German stock to German buyers are domestic and cannot go through OSS; only sales to other EU countries can.

Can I stay under €10,000 and ignore destination VAT? Only if you are established in one EU country and ship from it. Stock in an Amazon warehouse abroad takes you outside the threshold.

Does Amazon handle my VAT? Outside the EU: Amazon accounts for the sales VAT as deemed supplier, but you still register where the stock is. Inside the EU: the VAT is yours, though Amazon's paid VAT Services can file for you.

About this article

Sources, all read on 30 September 2026: European Commission, One Stop Shop, Register and Declare and pay; European Commission, Explanatory Notes on VAT e-commerce rules (published September 2020, not legally binding), section 2.1 and Q&A 1–21 of section 3.3; German law via gesetze-im-internet.de: § 1a, § 3, § 3c, § 18 UStG and § 1 UStZustV; Amazon, sell.amazon.de/versand-durch-amazon/europa, sell.amazon.de/informationen/steuerinformationen (German pages; quotes are our translation) and the "Rate Card — Europe Fees, effective as of 1st July 2026" (PDF), FAQ Q14. Our own facts are Avanta Global EOOD records from May–September 2026. Rules change; check the current versions before acting. We are not accountants, tax advisers or lawyers.