TOOG 2028 Declaration – deadlines, data, corrections and records
The TOOG declaration will be submitted monthly – even if no transfer covered by the procedure occurs in a given period.
The biggest challenge will not be the form itself, but collecting consistent data on physical inventory movements, value, currency, and adjustments.
Six things to remember
TOOG is responsible for reporting transfers of its own inventory. The rules for entering the procedure itself are explained separately in the TOOG 2028 guide – Movement of Own Goods. Until June 30, 2028, the current rules for IDT and INT of own inventory.
When to submit the TOOG declaration?
Pursuant to Article 369xf of the VAT Directive after the changes in ViDA, the settlement period is one month and the declaration is submitted by the end of the month following the reporting period.
Data collected for the first month of the procedure.
TOOG electronic declaration for July.
Next monthly billing period.
TOOG electronic declaration for August.
Route, value, period and identification
Commission Implementing Regulation (EU) 2026/1869 defines a common electronic data structure for the procedure.
The actual beginning of the movement.
Place of receipt of supplies.
Tax base excluding VAT.
Month of obligation.
If they were given.
This schematic diagram is based on the EU data structure and is not an official form. The final screen of the Polish TOOG system does not yet constitute the basis for this visualization.
TOOG declaration and records
The monthly report presents aggregated data. The records must allow for the reconstitution of the specific movements that generated the total.
Aggregated data
Example: Germany – €40,000 in transfers in a given month.
Detailed history
Each transfer, warehouse addresses, date, description, quantity, value, currency and subsequent changes.
How to determine the value of the goods being moved?
The rule in Article 76 of the VAT Directive refers to the purchase price or the price of similar goods, and in its absence, to the production cost determined at the time of transfer.
Subsequent sale price
The planned retail price of €99 is not automatically the transfer value.
Value according to Article 76
Purchase price, price of similar goods or – in the absence of a purchase price – production cost.
How to convert values in the TOOG declaration?
The directive specifies the euro, but a country outside the eurozone may require its national currency. Therefore, we are not currently determining whether the Polish system will be technically operated in euro or PLN.
How to correct an error in the TOOG declaration?
Select the moment when the error was detected. The correction rules arise from Article 369xg of the VAT Directive.
Select an answer
You will see the correct way to approach the correction.
When is a TOOG zero declaration filed?
Council Implementing Regulation (EU) 2025/518 provides for a nil declaration when there have been no transfers or corrections during a period.
You submit a monthly zero declaration.
This isn't a clean zero. The later declaration is used to show the correction to the earlier period.
Company with three routes in October 2028.
What counts is the actual physical movement of the inventory, not the country of residence of the company.
Stock position and stock movement
The mere fact that goods remain in a foreign warehouse does not create a new transfer each month.
Where is the goods now?
From where, where and when was it actually moved?
What data must be kept for 10 years?
The detailed information catalog follows the TOOG recordkeeping rules. The period is counted from December 31st of the year in which the transfer occurred.
Is your system ready for TOOG?
Select the data you can download today. This is a data readiness review, not a tax compliance assessment.
Available data: 0 of 9. The more data missing, the more integration work may be needed before TOOG.
What should the TOOG declaration workflow look like?
A repeatable process should combine logistics data, pricing, corrections and archiving.
Amazon FBA and 3PL – Relocation History Needed
For automated movements, a company should be able to retrieve the sequence: source warehouse → destination warehouse → date → SKU → quantity → value. We describe more about the logistics model in the article "VAT OSS, Amazon FBA, and foreign warehouses."
Amazon FBA
The operator's report must enable the reconstruction of relocations between centers in different countries.
Fulfillment / 3PL
Before 2028, it is worth checking the contract, the scope of data export and the possibility of retaining history after the end of cooperation.
First, check which transfers can enter TOOG
This guide covers reporting. Terms of use are described in the parent article.
What happens if you fail to submit your declaration?
The country of identification is to send an electronic reminder on the tenth day after the deadline. This is not an extension of the deadline. Repeated failure to submit a declaration or failure to provide records may be considered persistent violations of the rules and lead to exclusion from the procedure.
Check if your inventory reports are sufficient for your monthly declaration
We will analyze data sources, routes, pricing, adjustments, and how information is archived from Amazon, 3PL, WMS, and ERP.
Frequently asked questions about the TOOG declaration
From when will the TOOG declaration be submitted?
From 1 July 2028, taxpayers using the procedure will submit monthly declarations for qualifying transfers.
Will the TOOG declaration be monthly?
Yes. The billing period will be a calendar month.
What will be the deadline for the TOOG declaration?
By the end of the month following the month to which the declaration relates.
Is it necessary to submit a zero declaration?
Yes, if there were no transfers in the month and there are no corrections to previous periods.
What value of the goods is indicated in the declaration?
The purchase price or the price of similar goods, and in the absence of a purchase price, the cost of production determined at the time of transfer.
Is the subsequent sale price shown?
No. The subsequent sale to the customer is a separate VAT event.
Is it necessary to indicate the country of dispatch?
Yes, when a transfer starts in a country other than the country of identification, the relevant data on the country of dispatch is part of the report.
What currency will the declaration be in?
The euro is the rule, but a country outside the eurozone may require a national currency. The Polish implementation remains to be verified.
How to correct a previous declaration?
After the original due date, the correction is reported in a later return, generally up to three years after the original due date.
How long should records be kept?
For 10 years from December 31 of the year in which the transfer was made.
The form will be the end of the process, not the beginning
The declaration can only be prepared once the company has a complete monthly history of movements, values, currencies, and adjustments. The full context of the reform can be found in the ViDA 2028 guide.
