Transfer of goods abroad and VAT – ICT and ITC of own stock
No sale does not mean no VAT. The goods may still belong to the same company, and their transfer to another EU country may result in IDT in the country of departure and INT in the country of destination.
Moving your own goods abroad – the most important rules
Before VAT can be applied, it's necessary to separate the physical movement of inventory from subsequent sales. These four questions typically determine whether you're analyzing a standard transfer of your own inventory or an exception.
Whose goods are these?
If the inventory belongs to the same company before and after transport, the absence of an independent buyer does not exclude VAT effects.
Where is it from and where is it going?
IDT and INT concern flows between EU countries. Destinations outside the EU require an export and import analysis.
Why did he leave?
Stock for future sale is assessed differently than repairs, processing, trade fairs or temporary use of equipment.
Will the goods be returned?
An actual return of the same item may constitute an exception. Leaving it as stock requires further consideration.
Don't use the "crossing the border = always IDT" or "no sale = no VAT" logic. First, determine the purpose, ownership, route, and fate of the specific goods.
When is the movement of own goods an ICT?
In a typical model, a taxpayer, either independently or through an operator, moves goods belonging to their company from Poland to another EU country to continue to serve their business activities. Source: Ministry of Finance – WDT
Standard Transfer Terms
- the goods belong to the entrepreneur;
- before transport it is located in Poland;
- physically goes to another EU country;
- the transport is performed by the taxpayer or an entity acting on his behalf;
- the goods are to continue to serve the activities of the same taxpayer;
- there is no particular exception.
The warehouse and carrier may be external
The warehouse may be owned by Amazon, a 3PL, or a fulfillment operator. A freight forwarder may handle the transport. You're assessing the ownership and intended use of the inventory, not the building's ownership or the name of the carrier.
This isn't a sale between two companies. The owner remains the same, but VAT regulations attribute a single physical transfer to two corresponding events in two countries.
WNT in the country where the own goods are shipped
If the stock leaves Poland as a non-transactional IDT, the destination country analyzes the corresponding IDT. These are two tax treatments of the same transport. Source: Ministry of Finance – IDT
WDT
of own supplies
WNT
Don't put on the automatic
The standard model may require local VAT registration, but this obligation must be assessed for the specific country and flow. This is best done before shipment.
WNT can be amount neutral
Output and input VAT can be offset if full deduction is allowed. Amount neutrality does not eliminate the obligation to report the event.
This is a separate event
Selling from German stock to a customer in Germany or France requires separate qualification. OSS does not account for prior stock transfers.
For the German example, see also VAT rules in Germany and VAT registration in Germany. For other countries, the starting point is the VAT registration service abroad.
0% rate for non-transactional IDT
The mere fact that a flow is IDT is not sufficient to safely apply 0%. VAT identification, reporting, and evidence of actual transport must be combined.
Your own EU VAT number abroad
The company operates on the WNT side under a number assigned in the destination country. The number and its status should correspond to the actual settlement.
VAT-EU and JPK_V7
Intra-Community supplies must be recorded in appropriate records and summary information. Discrepancies between documents increase the risk of disputes.
Proof of export and delivery
The CMR, warehouse confirmation and operator report should clearly link the specific goods, date, route and place of receipt.
You can check the status of your number using the VIES tool – EU VAT number checker. However, a positive VIES result does not replace transport documents or other 0% rate conditions.
How to document the movement of your own goods?
The documentation should allow for the reconstitution of the goods, quantity, date, route, warehouse address and VAT numbers used on both sides of the transfer.
This isn't a sale between two companies. XXX moves 500 units of its own inventory to a warehouse in Germany and remains the owner.
Non-transactional transfer of own goods from Poland to Germany – Article 13, paragraph 3 of the VAT Act.
Tax document
- an invoice documenting the IDT in accordance with the current position of the National Tax Information Office;
- Polish and foreign VAT numbers of the same company;
- value and description of the transfer;
- connection with JPK and VAT-UE records.
Logistics trail
- CMR or other transport document;
- WZ, Stock Transfer or transfer order;
- confirmation of warehouse receipt;
- Amazon or 3PL report, SKU, quantities, dates and warehouse address.
Invoice, pro forma and KSeF for non-transactional IDT
In this part, the Act must be clearly distinguished from the position of the body expressed in an individual case.
Reference number 0114-KDIP1-2.4012.232.2026.2.GK. The authority took the position that the described non-transactional IDT should be documented with an invoice, and if the issuer is subject to the mandatory KSeF and there is no exemption – with a structured invoice. Source: KIS interpretation
This is not a change to the law
The interpretation is individual. It is not a general interpretation or a source of universally applicable law. It protects the applicant within the limits of the described situation.
It helps with logistics, it does not replace an invoice
The Ministry of Finance states that a pro forma invoice is not an invoice and is not submitted to the National Securities and Exchange Commission. It can remain an auxiliary document.
First, the exhibitor status
It's important to determine whether a specific taxpayer is subject to mandatory KSeF and whether they benefit from an exemption. The foreign number on the other end doesn't resolve this issue on its own. Source: Ministry of Finance – KSeF
| Document | Function | KSeF |
|---|---|---|
| Invoice | Documents the event in accordance with the current KIS position. | If the issuer is subject to obligation and no exemption. |
| Pro forma | May support transportation, pricing or clearance. | It is not sent to KSeF. |
| WZ / Stock Transfer | It connects goods, quantities, warehouses and the logistics process. | It is not a structured invoice. |
| CMR / warehouse confirmation | Proof of transport and receipt of goods. | It is stored outside KSeF. |
How to show the shift in JPK_V7 and VAT-UE?
A transfer classified as an intra-Community supply does not end with a warehouse document. Tax, transport, and warehouse data should form a single, coherent record. Source: Ministry of Finance – JPK structures
WDT basis
In the structures in force from February 2026, the basis for IDT goes to K_21 in the records, and in the declaration part it corresponds to P_21.
Your own foreign number
For example, PL → DE, the German VAT number of the same company is shown, not the number of Amazon or the 3PL operator.
One value and one date
Invoice, JPK_V7, VAT-UE, CMR and warehouse report should allow assigning the same value to the same transfer.
If the invoice shows PLN 50,000, VAT-UE PLN 55,000, and the operator's report shows a different number of SKUs, the documentation must be reconciled before sending the settlements.
Exceptions: why did the goods leave and what happens next?
The list of exceptions requires verification of the terms of the specific provision. Simply calling a transport "temporary" is not sufficient. Source: Articles 17 and 17a of the VAT Directive
| Flow | Typical direction of analysis | Key condition |
|---|---|---|
| Repair, processing, valuation | Possible exception to standard transfer. | The same goods are returned to Poland after the work is completed. |
| Temporary use | Possible exception for the provision of services or temporary admission. | A truly temporary goal and the fulfillment of specific conditions. |
| Trade fair and demonstration | They don't have to create foreign stock. | Documented return of equipment or goods. |
| Delivery with assembly | Separate rules for the place of taxation. | Transport is part of a specific delivery with installation. |
| WSTO | B2C sales, not a transfer without a buyer. | There is a customer and a sales transaction. |
| Reverse logistics | Return, inspection or repair may be a time flow. | It is necessary to determine whether the goods are being returned or become local stock. |
Poland → repair in Germany → Poland
What matters is the actual return of the same item after the work is completed. Document serial numbers, issue, service, and return.
Poland → repair → stock in Germany
If the goods are not returned after being repaired but remain as stock for further sale, the exception condition may no longer be met.
This period is a special exception related to the terms of temporary importation with full exemption from customs duties. It does not allow ordinary commercial stock to be left abroad for 23 months without an IDT/ICT analysis.
3PL Warehouse, Fulfillment and Amazon FBA
It's not crucial who owns the building. What matters is who owns the goods, where they are physically stored, and whether stock has been created there for further operations.
3PL / fulfillment
Amazon FBA
Amazon can move inventory between centers. The operator's decision does not automatically result in VAT neutrality. Verify the actual inventory country, date, center code, and transaction type.
BTS2 example: The arrival of goods at a returns center in Slovakia doesn't necessarily mean standard storage or transfer of your own inventory to be reported. The product's status, facility function, and further route must be determined.
Call-off stock vs. regular warehouse
The difference begins with the question of whether the specific buyer for whom the goods are being warehoused is known before transport.
Unknown future clients
The goods await orders from numerous future customers. This is a typical 3PL or FBA warehouse model and standard IDT/INT analysis.
Specific known buyer
The buyer, their VAT number, and the agreement are known before transport. Registration, VAT-EU registration, and receipt of the goods are generally required within 12 months.
Standard Amazon FBA inventory should not automatically be considered call-off stock: it is typically intended for many future, yet-to-be-identified customers. New call-off stock procedures can only be initiated until June 30, 2028; after that, they will be replaced by the broader TOOG mechanism. Source: ViDA Directive
TOOG from 1 July 2028 – what will change when transferring your own goods?
Transfer of Own Goods is intended to enable the reporting of eligible transfers through a special procedure linked to the OSS and limit some registrations resulting solely from ITC of own stock. Source: Regulation 2026/1869
A standard transfer requires an analysis of the ICT in the country of departure, the ICT in the country of destination and potential local registration.
Qualifying transfers are to be reported through the new procedure; WNT in the destination country is to benefit from an exemption.
It also doesn't mean that foreign VAT will never be required from 2028. Local sales, imports, purchases, or other transactions may still trigger registration requirements.
Moving your own goods outside the EU
Poland → Great Britain, Switzerland, or Norway is not an IDT + INT scheme. We need to switch to the logic of exporting from the EU and importing in the destination country.
Before shipping, determine the importer, customs value, delivery terms, and import VAT deduction eligibility. This can be verified by verifying the EORI number.
The most common mistakes when moving your own stock
Registration checked after transfer
The goods are already abroad when the company is just analysing the WNT and the local VAT number.
Amazon or 3PL as a buyer
The operator usually stores the goods; he does not thereby become their buyer.
OSS assigned to stock transfer
OSS can settle eligible ESPOs but does not replace the settlement of inventory IDT/IWNT.
No evidence of transport
The accounting document itself does not confirm that a specific product has reached the indicated country.
Pro forma only
A pro forma is not an invoice and, according to the KIS position, it does not replace a document for IDT.
No JPK_V7 or VAT-UE
A transfer treated as an IDT must also be reflected in reporting.
Each movement is treated as WDT
Repair, temporary use and reverse logistics may require exceptions.
Looking only at the marketplace
Amazon.de doesn't prove that the inventory is located in Germany. What matters is the physical location.
Failure to reconcile reports
Quantities, dates and warehouse codes from ERP, Amazon and 3PL should match.
“No sales = no VAT”
The mere movement of your own goods between EU countries may constitute a taxable event.
Checklist for transferring goods to a foreign warehouse
Are you planning to move your stock to a warehouse in another EU country?
Before the first transfer, it is worth determining VAT registration, the method of documentation and reporting of IDT/INT.
Useful Taxenlight Guides and Tools
Select the tool or guide you need. The entire tile is clickable and takes you directly to the specified page.
Moving goods abroad and VAT – FAQ
Not in the commercial sense, because the owner of the goods does not change. However, for VAT purposes, such a movement may be treated as an IDT in the country of departure and an INT in the country of destination.
Standard intra-Community acquisition of own goods may require local VAT registration. This obligation should be reviewed before the first transfer, taking into account the model and exceptions.
Yes, after meeting the conditions regarding, among others, EU VAT identification, VAT-EU information and documents confirming the export and delivery of goods to another EU country.
No. A pro forma invoice may support logistics, but it is not an invoice. In an individual tax ruling issued on June 30, 2026, the Director of the National Tax Information (KIS) determined that the described non-transactional IDT should be documented with an invoice.
According to the National Tax Information Service's position of June 30, 2026, an invoice documenting such IDT should be submitted to the National Tax Information Service (KSeF) if the issuer is subject to this obligation and does not avail itself of an exemption. This position stems from an individual interpretation, not a statutory amendment or a general interpretation.
Yes, if the transfer constitutes an intra-Community supply of goods under Article 13(3) of the VAT Act. The VAT-EU information uses the foreign VAT number of the same company in the country of destination.
Yes. When a seller's own inventory is moved between centers in different EU countries, the movement may require recognition of intra-Community supplies (ICS) and intra-Community supplies (ICS). The mere fact that Amazon organizes the transport does not determine VAT neutrality.
It's not just the warehouse address itself. What matters is the actual storage of your own inventory, the purpose of the transfer, and the subsequent fate of the goods. However, regular inventory at a foreign 3PL may require local registration.
No. Exceptions may apply to, among other things, repairs, processing, valuations, temporary use, delivery with installation, and some return shipments. The purpose, timing, and fate of the goods must be verified.
Not always. If the same goods are returned to Poland after the work is completed, an exception may apply. If they remain abroad as stock, the IDT and INT must be re-examined.
No. The limit applies to certain cross-border B2C sales and services. It does not exempt you from VAT analysis when moving your own inventory to a foreign warehouse.
No. The Transfer of Own Goods procedure is to be applied from 1 July 2028. Until then, transfers of own inventory are settled according to the current IDT and INT rules.
No. Flows from Poland to the UK, Switzerland or Norway require an analysis of EU exports and imports in the destination country, including EORI, importer, import VAT and possible customs duties.
