Amazon FBA vs. ViDA and TOOG from 2028 – will VAT registration still be required?
Amazon FBA from 2028 doesn't automatically mean the end of foreign VAT numbers. However, TOOG, extended Union OSS, and reverse charge may eliminate some of the most common reasons for local registration.
First, determine why your company has a VAT ID in a given country. Only then should you check whether a specific obligation can be covered by one of ViDA's mechanisms.
First the reason for registration, then the actual mechanism
ViDA doesn't "exclude VAT" for FBA. It separates responsibilities that are often combined in a single local number.
The full reform roadmap, timeline, and interdependencies between mechanisms are described in the ViDA 2028 e-commerce. The Commission confirms the launch of the Single VAT Registration reform on July 1, 2028, in the official ViDA timeline.
Why do you have a VAT number in this country?
Select all reasons. The result provides appropriate analysis paths but never replaces the decision to deregister.
Mechanisms to check
Please select at least one reason for having a VAT number.
The result doesn't say "close VAT ID." After going through all the branches, you need to check whether there's at least one other reason for registration, a historical obligation, or the need to settle input VAT.
Amazon FBA today vs July 1, 2028.
The model shows eligible flows. Imports, other local transactions, or failure to meet the conditions may still require VAT DE.
Transfer and local sales cumulate responsibilities
Two procedures can take over two responsibilities
Article 369xi of the VAT Directive provides for the exemption of intra-Community acquisition of goods in the country of destination under the TOOG. The detailed conditions of the procedure itself remain in the separate TOOG 2028.
TOOG, OSS and reverse charge are responsible for different events
Single VAT Registration isn't a single number or a single declaration. It's a set of solutions for separate stages.
PL → Amazon DE
Qualifying transfers of own goods may be included in TOOG. Reporting is performed in a separate procedure.
Amazon DE → consumer DE
A specific local shipment may be included in the extended Union OSS. It is not an STO because the goods do not cross the border when sold.
Amazon DE → VAT registered company DE
Transactions should not be automatically uploaded to the OSS. Article 194, VAT identification, and supplier establishment status should be checked.
Connect Amazon FBA to the full ViDA 2028 map
Check the schedule, TOOG, extended OSS, reverse charge and the impact of the reform on local registrations.
Don't show the entire route as PL → IT
A single inventory can generate a series of consecutive transfers of its own goods. Each cross-border arrow requires separate analysis.
Each section has its own date, quantity, value, country of dispatch, and country of destination. The current IDT/ICT mechanism is described in the article " Moving Own Goods Abroad and VAT.
The warehouse condition does not explain how the goods ended up there
For transfer settlement, the movement history is more important than a single end-of-day inventory image.
Where is the goods now?
Example: 300 pieces in DE and 200 pieces in FR. The report does not indicate where, when, or in what batch the stock arrived.
How and when did the goods arrive at the warehouse?
Example: 100 pieces of SKU-123 were transferred from DE to FR on August 4. This record allows us to reconstruct a specific transfer.
TOOG requires a history of stock movements, not just current inventory levels. Therefore, the inventory ledger report should be reconciled with the ERP and subsequent sales.
Traffic information does not mean that the operator has taken over the billing
The seller will not settle the transfer correctly if he does not know that his goods have changed country.
Article 242b of the VAT Directive requires that information about a specific transfer be communicated to the owner at the latest upon transport or shipment. It does not stipulate that Amazon will automatically settle TOOG for the seller.
Every transfer should be reproducible
The minimum operational requirements are route, date, product, and quantity. Value and currency data are also required for declarations and records.
Detailed recording rules are developed in the TOOG Declaration 2028. The scope of data results, among others, from Council Implementing Regulation (EU) 2025/518, and the format of new messages is further specified in Commission Implementing Regulation (EU) 2026/1869.
Not sure which country the center code in your report is located in? Use Amazon's European warehouse to check whether the facility is an FC, IXD, Returns Center, or another type of location.
China → Amazon DE is not a transfer of own goods in the EU
First, the goods enter the EU. Only subsequent relocations between member states can trigger a TOOG analysis.
New import rules and the EU Customs Data Hub describe a separate pillar of the 2028 EU customs reform for e-commerce. TOOG does not replace clearance, customs, or import VAT analysis.
Amazon DE can launch four separate VAT paths
The classification depends on the actual route of the goods and the status of the recipient, not on the name of the FBA program itself.
The current rules for the warehouse model remain in the article VAT OSS, Amazon FBA, and overseas warehouses. This guide focuses solely on the changes from 2028 and the future of VAT ID.
Local B2B sales will not always pass on to the buyer
The basic, mandatory reverse charge under the new Article 194 has specific conditions. One of them is the lack of local individual VAT identification of the foreign supplier.
The supplier is not established locally
Status must be determined for a specific model. A warehouse or VAT number alone does not automatically determine a permanent place of business.
The supplier does not have a local VAT ID
In the basic version of Article 194, the individual local identification of the supplier is relevant for the application of the mandatory mechanism.
The buyer is locally identified
The buyer must meet the conditions for assuming the obligation to settle VAT.
Therefore, you must not write "local B2B after 2028 always reverse charge." If the company still has VAT DE due to import or other activities, the result may be different. The legal basis is provided by the amended Article 194 of the VAT Directive.
Warehouse, VAT ID and fixed establishment are not the same
Do not determine establishment status solely based on the fact that Amazon stores inventory in a given country.
Warehouse
Shows the location of the physical inventory and the starting point for transfer or subsequent sale.
Local VAT ID
It is used for specific tax purposes. The number itself does not constitute proof of local establishment.
Fixed establishment
It requires a separate analysis of resources, organization and use of the structure in specific transactions.
Map of mechanisms instead of the "VAT ID to be closed" column
Each country should have its own set of reasons for registration. The table below is an example of an audit structure, not a result for a specific company.
| Country | Stock | Transfers | Local B2C | B2B | Import / other | What to check from 2028 |
|---|---|---|---|---|---|---|
| DE | Yes | Yes | Yes | Yes | check | TOOG + OSS + RC + import |
| CZ | Yes | Yes | Yes | NO | check | TOOG + OSS |
| FR | Yes | Yes | Yes | Yes | check | TOOG + OSS + RC |
| IT | Yes | Yes | NO | Yes | check | TOOG + RC |
Only after all activities have been assigned can you assess whether a specific number still has a function. For a general comparison of procedures, see the article "VAT OSS or VAT registration abroad."
Go through each registration reason separately
The tree does not automatically recommend deregistration. It shows the order of questions.
The audit begins with a map of the warehouses and the reasons for each VAT ID
Fewer numbers don't mean less control over stock. Data will need to connect traffic, subsequent sales, and billing methods.
1. Warehouses
Determine the countries, facility codes, and type of each Amazon location.
2. Transfers
Recreate every movement from where → to where → when → SKU → quantity → value.
3. Sales
Separate local B2C, WSTO, local B2B and other transactions.
4. VAT ID
Assign each number all the reasons for having it, including import and input VAT.
We will check every warehouse, transfer and reason for foreign registration
We'll analyze Pan-EU FBA, automatic relocations, B2C and B2B sales, imports, input VAT, and Amazon data. The result will be a map of obligations for each country—not an automatic recommendation to close your VAT ID.
Amazon FBA VAT 2028 FAQ
Will Amazon FBA no longer require foreign VAT from 2028?
This general rule cannot be adopted. TOOG, extended OSS, and reverse charge may eliminate some of the reasons for local registration, but imports, other transactions, or procedural failures may still require a VAT ID.
Will the PL → Amazon DE transfer be settled via TOOG?
If the movement meets the conditions of the new procedure for transfers of own goods, it may be covered by TOOG from 1 July 2028.
Can Amazon DE → CZ transfer be TOOG?
Such a relocation must be analyzed as a separate transfer. If the owner of the inventory remains the same and all other conditions are met, the transfer may qualify for TOOG.
Is DE → DE transfer TOOG?
No. Goods do not change Member States. TOOG applies to transfers of own goods between EU countries.
Will Amazon DE sales → DE client be in OSS?
From 1 July 2028, certain local B2C supplies made by a taxpayer not established in the taxing country will be able to enter the extended Union OSS.
Will Amazon DE sales → VAT DE company be in OSS?
It should not be automatically reported in the OSS. For local B2B sales, the conditions of Article 194 and the reverse charge, among others, must be examined.
Will local B2B sales with FBA always be reverse charge?
No. The mandatory mechanism has specific conditions, including the lack of local establishment and, in the basic variant, the lack of an individual local VAT ID for the supplier.
Will Amazon inform about stock relocation?
Article 242b provides for the obligation to notify the owner of a specific transfer made by another taxpayer without the owner's express request. However, this does not mean that the operator will automatically settle the TOOG.
Can import to an Amazon warehouse be settled via TOOG?
No. The entry of goods from a third country into the EU constitutes an import. Only the subsequent movement of own stock between Member States may require a TOOG analysis.
Can a foreign VAT ID be closed on July 1, 2028?
Not automatically. You need to analyze all the reasons for having the number, account for previous periods, and carry out the appropriate deregistration procedure if the number becomes redundant.
Don't ask if FBA "requires VAT"
Determine why you need each number and which element of ViDA can replace that specific obligation from July 1, 2028.
