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Moving Your Own Goods Between EU Warehouses: VAT Rules for Bulgarian Companies
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Moving your own goods between EU warehouses can create VAT obligations even when no actual sale takes place. This is especially important for Bulgarian companies that send their own products from Bulgaria to a warehouse or fulfilment centre in another EU Member State.
At first glance, this may look like a simple logistics operation. For VAT purposes, however, it can be treated as a cross-border transaction that must be reported correctly. This is why the VAT implications should be reviewed before the goods leave Bulgaria.
Why Can Moving Your Own Goods Create VAT Obligations?
Under EU VAT rules, when a taxable person transfers business goods from one Member State to another, the movement is generally treated as an intra-Community supply in the country of departure.
At the same time, a corresponding intra-Community acquisition may arise in the country where the goods arrive. This means that VAT reporting obligations can arise even when:
- the company remains the owner of the goods;
- there is no specific customer at the time of the transfer;
- no sales invoice is issued to another buyer;
- no payment is received;
- the goods are stored by an external logistics or fulfilment provider.
For example, a Bulgarian company sends its own products to a fulfilment warehouse in Germany. The products remain the property of the Bulgarian company until they are sold to customers.
Even though there is no sale to the warehouse, the physical movement of the goods from Bulgaria to Germany can still create VAT obligations.
Can VAT Registration Be Required in the Destination Country?
A Bulgarian VAT number is not always sufficient when company-owned goods are stored in another EU country. Because the transfer may create an intra-Community acquisition in the country of arrival, the business may need a local VAT registration or a local VAT identification number.
The last point is particularly important when using large fulfilment networks such as Amazon. If your business uses this model, read our detailed guide to Amazon FBA EU VAT for Bulgarian companies.
The exact procedure depends on the country where the warehouse is located. Before shipping the goods, the company should check:
- which VAT number should be used for the dispatch;
- which VAT number should be used in the destination country;
- how the movement must be reported in Bulgaria;
- which reporting obligations apply in the country of storage;
- how subsequent sales from that warehouse will be treated.
Which Documents Should Be Kept?
The documentation should clearly show what goods were moved, when they were dispatched, where they arrived and who owned them throughout the process. A clear audit trail is important both for accounting purposes and in case of a VAT inspection.
- transport documents and carrier confirmations;
- CMR documents, where applicable;
- warehouse receipt or intake confirmations;
- internal stock transfer documents;
- product codes, SKU numbers and descriptions;
- quantities of transferred goods;
- dispatch and arrival dates;
- the value used for accounting and VAT purposes;
- records of returned, missing, destroyed or adjusted stock.
The quantities removed from the Bulgarian inventory records should match the quantities received in the foreign warehouse. Unexplained differences between the two systems may create problems during a tax review.
Practical VAT Check for Moving Goods Between EU Warehouses
| Situation | Possible VAT Treatment | What to Check |
|---|---|---|
| Goods are moved from Bulgaria to the company’s own warehouse in another EU country | An intra-Community supply may arise in Bulgaria and an intra-Community acquisition in the destination country | VAT registration, VAT numbers used and correct reporting of the movement |
| Goods are sent to a fulfilment centre in another EU country | Using an external warehouse operator does not automatically remove VAT obligations | Who owns the goods, where they are physically stored and how the movement is reported |
| Goods are sold after arriving in the foreign warehouse | The sale may have different VAT treatment depending on the customer and the place from which the goods are dispatched | Local VAT reporting, OSS applicability and customer status |
| Part of the stock is returned to Bulgaria | The return movement may also require separate VAT and accounting treatment | Transport documents, warehouse records and correct quantity reconciliation |
| Goods are missing, destroyed or adjusted | VAT consequences and additional documentation requirements may arise | Reason for the adjustment, supporting evidence and consistency between warehouse and accounting records |
Does OSS Remove the Need for Local VAT Registration?
Not always. The One Stop Shop, or OSS, simplifies the reporting of certain cross-border B2C sales within the EU. However, it does not automatically remove other VAT obligations when a company transfers and stores its own goods in another Member State. For example, a sale to a private customer from a foreign warehouse may, in certain circumstances, be reported through OSS. The earlier movement of the goods into that warehouse is still a separate VAT event.
Sales to customers in the country where the goods are physically stored may also create local VAT obligations. Under the VAT in the Digital Age reform, a special scheme for transfers of own goods is scheduled to apply from 1 July 2028. Until the new rules become applicable, businesses should continue to assess VAT registration and reporting obligations under the current system.
When Is Call-Off Stock Different?
Call-off stock is a different arrangement.
It may apply in specific circumstances where goods are moved to another Member State for a particular business customer who is identified in advance and all legal conditions are met. This is not the same as sending general inventory to your own warehouse or fulfilment centre for future customers who are not yet known. For this reason, the call-off stock simplification should not automatically be assumed to apply to every warehouse transfer.
What Should You Check Before the First Shipment?
Before moving the goods, review the entire supply chain. Identify:
- the country from which the goods are dispatched;
- the country where the goods will be stored;
- who remains the legal owner of the goods;
- which VAT numbers will be used;
- where future customers are located;
- how subsequent sales will be reported;
- whether the logistics provider may move the stock between different EU countries.
The last point is particularly important when using large fulfilment networks. If a logistics provider moves stock from one EU warehouse to another, a new cross-border movement may arise and should be reviewed separately. Warehouse reports, accounting records and VAT returns should be consistent and easy to reconcile.
ASB Accounting Services Bulgaria can assist with reviewing warehouse structures, identifying potential VAT registration obligations and coordinating accounting and VAT reporting for cross-border stock movements within the European Union. Learn more about our tax and accounting consulting services in Bulgaria.
This article provides general information only and does not constitute tax, accounting or legal advice. The correct VAT treatment depends on the specific facts of each supply chain and the national rules of the Member States involved.