Fulfillment and 3PL warehouse abroad and VAT
A foreign 3PL provider does not automatically become the buyer of the goods and does not assume the seller's VAT obligations. Storage, packaging, and shipping are logistics services, and inventory and sales must be accounted for separately.
The key factors are: the country where the goods are located, transfers between warehouses, customer status, delivery direction and the operator's service invoice.
For a general comparison of models, see the guide: Warehousing Abroad and VAT. Here, we focus on the external fulfillment operator.
What to check before you ship your first batch?
- Shipping your own inventory to another country may result in IDT and INT.
- The operator provides the service but does not usually settle VAT on your inventory and sales.
- Local sales, WSTO and B2B require different settlement methods.
- OSS does not automatically cover inventory transfer or domestic sales.
- Without location, relocation, and return reports, accurate billing may be impossible.
Owner of the goods
Accounts for transfers, sales, and local VAT obligations unless the model specifies a different seller.
Logistics operator
It receives, stores, assembles and ships inventory and provides data required for billing.
Client
Its status and country of delivery influence the qualification of the sale as local, STO or B2B.
Administration
Expects consistency in declarations, transport documents, warehouse reports and invoices.
The examples assume ordinary commercial goods, a Polish company, and no specific exemptions. Imports, excise duties, regulated goods, and multi-entity structures require separate analysis.
What is fulfillment and how does it differ from a 3PL warehouse?
Fulfillment encompasses the entire order fulfillment process. 3PL involves entrusting some or all of the logistics to an external operator.
| Concept | What does it describe? | Example activities |
|---|---|---|
| 3PL Warehouse | External logistics operator | Receipt, storage, issue |
| Fulfillment | The entire process from inventory to customer delivery | Pick & pack, shipping, returns, SLA |
| Dropshipping | Model without own retailer inventory | The supplier or operator ships directly to the customer |
| Cross-docking | Short transhipment storage | The goods are quickly sent for further shipment |
| Marketplace Magazine | Sales platform infrastructure | Storage and execution of platform orders |
Is the 3PL warehouse the seller's own warehouse?
Not in the civil law sense, if the company uses only the operator's service. The goods may still belong to the seller, and the operator performs technical tasks on their behalf.
What is most important for VAT?
Not the name of the service, but the ownership of the goods, the country of stock, the direction of transport, the customer's status, the content of the contract and the actual course of action.
Is a 3PL operator a service provider or a buyer of goods?
In standard fulfillment, the operator stores, packages, and ships products on behalf of the seller. The buyer is the end customer or other contractor.
The operator is a service provider
- does not purchase supplies on its own account;
- does not independently determine the price and recipient;
- receives remuneration for receipt, storage, packaging and shipping;
- reports the movements of goods belonging to the seller.
The operator may be the buyer
- buys the goods and bears the commercial risk;
- he disposes of it freely;
- conducts further sales himself;
- issues its own sales documents to the customer.
Then check carrier delivery, distribution model or chain delivery.
What should be included in the contract?
Ownership and risk
Owner of inventory, risk of theft and damage, liquidation rules and insurance.
Location and relocations
Addresses of centers, countries of shipment, operator's right to transfer goods and notification obligation.
Data and documents
Reports on receipts, stocks, sales, returns and transfers and their submission dates.
When does shipping to a foreign 3PL result in IDT and INT?
If a Polish company moves its own stock to a warehouse in another EU country, the transfer of its own goods must be analysed, even if the operator does not buy anything.
Example: 500 pieces in Germany
Alfa, VAT PL, ships 500 products to a German 3PL. The goods still belong to Alfa. First, the Poland-to-Germany transfer is analyzed, followed by each sale from the German inventory.
Does a service or temporary use exception work?
It may be used in specific situations, such as for identifiable goods being returned after completing a specific job. It should not automatically be applied to regular storage for future customers.
The European Commission describes the transfer of own goods under the VAT Directive. Documenting the movement is expanded upon in the article " Moving goods abroad and VAT.
Does a foreign 3PL warehouse require VAT registration?
Often yes, but the answer depends on the transfer of the stock, subsequent sale, import, exceptions and local regulations.
No sales yet
Obligations may arise already when moving own stock and ITC in the warehouse country.
Sale from stock
Local deliveries, onward transfers and activities outside the OSS may require a number and declaration.
The operator does not replace the seller
Its VAT number applies to the operator's services and does not automatically take over the ITC or sale of the stock owner.
Does the warehouse constitute a permanent place of business?
Neither the operator's address nor the foreign VAT number alone determines a permanent location. The analysis includes permanence and the operator's own or available human and technical resources to participate in transactions.
- the right to use certain infrastructure;
- the ability to issue binding instructions to staff;
- resources that are constantly available;
- control over inventory and the sales process;
- ability to receive and use services for business purposes.
How to settle VAT on goods and invoice for fulfillment?
Receiving, storing, picking, packaging, and shipping are services. Product delivery and the transfer of our own inventory are separate events.
VAT on goods
- transfer of own stock;
- local sales;
- WSTO to the consumer;
- WDT to the company;
- return, relocation or liquidation.
VAT on 3PL services
- receipt and storage;
- pick & pack;
- transport or its organization;
- returns handling;
- place of supply and possible reverse charge.
| Event | Subject of the activity | Separate VAT analysis? |
|---|---|---|
| Receipt and storage | Warehouse service | Yes |
| Pick & pack | Logistics service | Yes |
| Shipment | Transport or fulfillment element | Yes |
| Goods for the customer | Delivery of goods | Yes |
| Stock transfer | Relocation of company assets | Yes |
| Return | Movement of goods and possible correction | Yes |
Basic B2B rule
The place of taxation for services is generally linked to the registered office of the customer-taxpayer. A foreign operator can issue an invoice without its own VAT, and the Polish buyer can settle the import of services after checking the status of the parties and exceptions.
The basis is described by the European Commission in its place of taxation rules.
Real estate service?
Not every warehousing arrangement automatically ties to a specific property. It depends on whether the client receives exclusive rights to a designated space or purchases a comprehensive logistics service.
Don't automatically record every 3PL invoice as a service import. First, classify the actual service provided.
Does OSS cover sales from a foreign 3PL warehouse?
OSS can cover qualified STOs but does not replace the transfer of own inventory, local sales, B2B, import, or operator service settlement.
Where and to whom does the goods go?
First, determine the warehouse country, customer country and customer status.
OSS may apply
Consumer in another EU country, transport starts in the country of the warehouse and the transaction meets the ESPO conditions.
OSS does not cover the event
Transfer of own inventory, domestic sales, B2B, import or fulfillment service.
| Warehouse country | Client | Typical qualification | OSS? |
|---|---|---|---|
| Germany | Consumer in Germany | Domestic sales in Germany | Not for the average salesperson |
| Germany | Consumer in France | WSTO Germany → France | Yes, after meeting the conditions |
| Germany | VAT company in France | WDT Germany → France | NO |
| France | Consumer in Poland | WSTO France → Poland | Yes, after meeting the conditions |
| France | Consumer in France | Domestic sales in France | Not for the average salesperson |
| Poland | VAT company in the Czech Republic | WDT Poland → Czech Republic | NO |
The €10,000 threshold applies to certain cross-border B2C supplies, not warehousing. A prior transfer from Poland to Germany remains a separate event. See the Ministry of Finance's information on OSS and IOSS.
How to settle sales when an operator has several warehouses?
For each sale, assign the warehouse country, customer country, customer status and actual transportation origin.
The address of the 3PL headquarters is not enough
- physical parcel release center;
- date of issue and customer country;
- carrier and shipment number;
- pre-order relocation;
- place of acceptance of the return.
Report per order or SKU
If the system automatically selects a center, a consolidated sales report may not be enough. You need data that allows you to assign each shipment to the country from which the goods actually originated.
The Amazon Pan-EU, EFN and CEE and VAT and Zalando and VAT guides compare the operation of platform warehouse networks – ZFS and ZEOS .
How to settle returns and relocations between 3PL warehouses?
The refund in the sales system does not yet show where the product physically ended up and in which country it will be sold again.
Return to the same center
Link sales adjustments to restocking and product status.
Return to another country
Check the movement of goods, possible stock transfer and impact on local records.
Repair or disposal
Document repair, repackaging, re-release, discount, or disposal.
Relocation within the same country
A transfer from one warehouse in Germany to another is not considered an IDT because the goods do not cross the border. It may still be relevant for inventory, Intrastat, and fixed-location analysis.
Relocation Germany → France
It can be another transfer of your own goods. You'll need the issue and receipt dates, value, and VAT numbers used in both countries.
Pooled inventory
A shared physical area is possible, but the system must identify the owner, country, SKU, batch, and transfer numbers. A shared area must not imply a loss of traceability.
What about importing into a 3PL warehouse and customs warehouse?
When delivering from outside the EU, customs duties and the status of the goods are added to the VAT analysis.
Determine before transport
- who is the importer and has EORI;
- who submits the customs declaration;
- where the import takes place;
- who pays customs duty and import VAT;
- whether after import the goods are sent to another country;
- who keeps customs documents.
Fulfillment is not a customs warehouse
A standard 3PL warehouse does not automatically obtain customs warehouse status. Customs warehousing is a special procedure for non-EU goods at an authorized location under official supervision.
Check official information about the EORI number , the service of obtaining an EORI in PUESC and customs warehousing rules .
What reports should a 3PL operator provide?
The sales report tells you what was sold. The inventory movement report shows where the goods were located and when. For VAT purposes, you need both.
| Report | What is it for? |
|---|---|
| Sales report | Sales, Customer, Price and Order Date |
| Inventory report | Stock by country and center |
| Inbound report | Receipt of goods into the warehouse |
| Stock movement report | Relocations between centers and countries |
| Returns report | Returns and Re-acceptance Location |
| Destruction report | Shortages, damage and disposal |
| Invoice report | Operator services and logistics fees |
Minimum fields in the inventory report
Identification
Stock owner, SKU, EAN, batch or other identifier.
Movement
Quantity received, issued, returned, reallocated and disposed of.
Location
Country, center address, dates of issue and acceptance.
Link
Transfer or order number, destination and status.
3PL, own warehouse or dropshipping?
There is no single "better tax" model. The best model is one in which a company can recreate the country of origin and assign sales to the correct return.
| Criterion | External 3PL | Own warehouse |
|---|---|---|
| Investment | Usually lower at the start | Improved infrastructure and staff |
| Flexibility | Easier scaling | More control, slower change |
| VAT data | Depends on operator reports | Dependent on your own system |
| Relocations | The operator can change the center | The entrepreneur controls the traffic |
| Sale | The responsibility usually remains with the seller | The responsibility remains with the seller |
| Logistics | Separate invoice and VAT analysis | Own operating costs |
What most often complicates fulfillment abroad?
Operator selected only by price
A cheap service without a warehouse country report may create higher tax and administrative costs.
Analysis only after stocking
VAT registration and reporting preparation may be required before the first transport.
The operator is treated as a buyer
Storage does not constitute purchase. Check the contract and the moment of transfer of title to the goods.
One settlement for goods and services
The stock transfer, sale, and operator invoice are separate events.
All sales at OSS
OSS does not automatically cover transfers, local sales or B2B.
No relocations or refunds
The item may change country and become available for sale again.
"Customs warehouse" without procedure
Regular fulfillment is not a customs warehouse, and shortages and liquidations also require documentation.
What to prepare before signing the contract and shipping the goods?
For each country and stage, assign a VAT number, declaration, OSS or local settlement, WDT/WNT, transport document, deadline and responsible person.
| Stage | Question | Document |
|---|---|---|
| Purchase or production | Who owns the goods? | Invoice or production document |
| Transport to 3PL | From which country and to which center is the supply going? | Order, WZ, CMR |
| Adoption | When did the operator accept the goods? | Inbound report |
| Storage | Where is the balance? | Inventory report |
| Relocation | Has the product changed country? | Stock movement report |
| Sale | Who is the customer and where did the package come from? | Sales/order report |
| Return | Where did the product return? | Returns report |
| Import | Who is the importer? | Customs declaration, EORI |
| Service | How to classify an operator invoice? | Invoice, contract, scope of services |
Operator and contract
- role of service provider or buyer;
- stock owner;
- the right to relocation;
- returns, shortages and liquidations;
- data per country and center.
VAT and sales
- transfer of own stock;
- local registration;
- B2C, B2B and domestic sales;
- OSS deliveries;
- status deemed supplier.
Imports and returns
- importer and EORI;
- status of goods;
- place of return;
- relocation of returns;
- damage and disposal.
Systems and reports
- warehouse country from/to;
- balance reconciliation;
- data before declaration;
- all sales channels;
- data storage period.
Are you planning fulfillment abroad?
Before shipping the first batch, we can sort out the goods flow, VAT numbers, OSS usage, operator invoice and data needed for declarations.
ViDA, TOOG and sales from a foreign warehouse
The reform may limit some registrations related to transfers of own stock and extend OSS to certain domestic deliveries. Until the new rules come into effect, current obligations will remain in place.
Transfers of own goods
The future procedure is described in the TOOG 2028, and the reform schedule is described in ViDA 2028 for e-commerce.
Domestic sales from foreign stock
The Union OSS extension is discussed in the article VAT OSS from 2028 - Domestic sales from foreign warehouse.
Further analysis according to the logistic model
Fulfillment and 3PL Warehousing Abroad - FAQ
Does the 3PL operator settle VAT for the seller?
Not automatically. The operator may provide data and services, but inventory and sales responsibilities typically remain with the owner of the item, unless the model specifically states otherwise.
Does a 3PL warehouse abroad mean VAT registration?
It can mean. This depends on the transfer of your own goods, sales, imports, local regulations, and any simplifications applied. Perform this analysis before stocking.
Is a fulfillment invoice an import of services?
It can be, but you need to determine the type of service, the status of the parties, the place of performance, and any exceptions. Don't automatically record every warehouse invoice the same way.
Is the warehousing service always taxed in the country of the warehouse?
No. For B2B services, the basic rule links the place of taxation to the customer's registered office, but exceptions depend on the nature of the service and the right to a specific area.
Will OSS settle sales from the 3PL warehouse?
It can settle a qualifying ESPO, but not a transfer of its own inventory or a regular domestic sale to a customer in the same country.
Can 3PL be call-off stock?
Yes, but only after meeting the procedural requirements and with a previously identified buyer. Regular stock for unknown customers is not call-off stock.
Does changing a 3PL warehouse to another country result in VAT?
This may result in another transfer of your own goods. You need a relocation report, receipt date, and inventory value.
Does the return to Poland automatically correct the ITA abroad?
No. Check how the return was documented and whether previous declarations actually require correction.
Does the 3PL operator create a permanent place of business?
The operator's address alone doesn't determine this. It's important to examine sustainability, human and technical resources, and actual control over the business.
Is the fulfillment warehouse a customs warehouse?
No. A bonded warehouse requires a separate procedure and customs supervision. A standard 3PL warehouse does not automatically have this status.
Are Amazon FBA, ZFS, and independent 3PL billed the same?
No. All models require inventory locations to be established, but platforms have their own programs, reports, and transaction roles.
Legal notice: the material is for informational purposes only and does not replace the analysis of the contract with the operator, goods routes, customer status, warehouse data or state stock regulations.
