Amazon Pan-EU without foreign VAT numbers: the transfer scheme

Now: a VAT number in every stock country

Moving your own goods to a warehouse in another EU country is now a transfer: an intra-EU supply from the Netherlands and an acquisition in the country of arrival. You register in that country, and you declare sales from that stock to consumers there. With Amazon Pan-EU that is often several countries, such as Germany, Poland and the Czech Republic.

From 1 July 2028: the transfer scheme

The scheme is in the Dutch act published on 19 October 2026 (Stb. 2026, 327). The implementing rules are in Implementing Regulation (EU) 2026/1869.

• You report all your transfers to other EU countries in one report to the Dutch tax authorities; you no longer need to register in the country of arrival for them
• The report is monthly, due by the end of the following month, with the amount per country of destination, also for a month without transfers
• The scheme applies only to goods for which you would have a full right to deduct VAT in the country of arrival
• Once you opt for the scheme, it applies to all your transfers

When you then sell the goods from that stock to consumers, you declare those sales through the Union OSS scheme, per quarter, also from the Netherlands.

What cannot go through the OSS

VAT you pay in another country, for example on purchases there, cannot be deducted in the OSS. You reclaim it with a refund request. Sales from foreign stock to businesses are usually reverse-charged to the customer; from 1 July 2028 that reverse charge is mandatory across the EU if the customer has a VAT number there.

How to prepare

• An overview of your current foreign VAT numbers, filing frequencies and costs
• Which goods you move where, and whether you have a full right to deduct VAT there
• When to close each foreign registration, so that no period is covered twice or not at all
• Call-off stock: that arrangement ends for goods transported after 1 July 2028

Example

A Dutch webshop sells through Amazon Pan-EU and has VAT numbers in Germany, Poland and the Czech Republic. In one month Amazon moves stock worth € 30,000 to those countries, and the webshop sells € 25,000 (excl. VAT) from that stock to consumers there.

• Now: three foreign registrations, each with an acquisition and a return for the sales
• From 1 July 2028: one monthly report in the Netherlands of the € 30,000 in transfers, split per country
• The sales of € 25,000 go into the quarterly OSS return in the Netherlands, at the VAT rate of each country
• The three foreign VAT numbers can be closed, if there is no other reason to keep them

This is a worked example, not a client case. Whether your foreign registrations can really go depends on your full flow of goods.

What we do

We list your foreign registrations, transfers and sales now, and work out what the new scheme saves you. Before 1 July 2028 we sign you up for the transfer scheme and the OSS in the Netherlands (€ 225 one-off), and then file the OSS returns (€ 175 per quarter). For the monthly transfer report we agree a fixed fee in advance. We reclaim foreign VAT for € 195 per country per year. Closing foreign registrations we arrange with local specialists.