Storing Goods in the EU?

Storing Goods in the EU? You May Need Another VAT Registration

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A Bulgarian VAT number does not automatically cover every VAT obligation your business may create across the European Union.

This becomes especially important when you start storing goods outside Bulgaria. A warehouse in Germany, Poland, the Netherlands or another EU country may look like a simple logistics decision. From a VAT perspective, however, moving your stock can create a taxable event before you have sold a single product to a customer.

This is where many businesses get caught out. They focus on the sale and overlook the movement of the goods that happened earlier.

If your company uses a foreign warehouse, fulfilment centre or marketplace logistics network, you need to understand where your stock is physically located, how it got there and where it goes next. These facts can determine whether another VAT registration is required.

Moving your own goods can create a VAT obligation

Imagine a Bulgarian company that owns stock in Sofia. It decides to move part of that stock to a warehouse in Germany so that German and other European customers can receive orders faster.

No customer has bought the goods yet. The company still owns them before and after the transfer.

It may therefore seem that nothing has happened for VAT purposes. Under the current EU VAT system, that assumption can be wrong.

A transfer of a business’s own goods from one EU Member State to another is generally treated as an intra-Community transaction. In broad terms, the business reports a deemed intra-Community supply in the country from which the goods leave and a corresponding intra-Community acquisition in the country where the goods arrive.

In our example, the arrival of the stock in Germany can therefore create German VAT compliance obligations for the Bulgarian business. This may include the need for a German VAT registration and local reporting even though the company remains established in Bulgaria.

The important point is simple: the VAT issue can arise when the goods move, not when the first customer places an order.

What happens when you start selling the stored goods?

Once the stock is in another EU country, the VAT treatment of the following sale depends on where the goods are located, where they are sent and who buys them.

This is why the physical movement of stock matters just as much as the invoice. Two sales made by the same Bulgarian company can have very different VAT treatment because the goods start their journey from different countries.

OSS helps with some sales, but it does not solve every warehouse VAT issue

The Union One Stop Shop, commonly known as OSS, can simplify VAT reporting for qualifying cross-border sales to consumers in the EU.

For example, if goods are stored in Germany and then shipped to a private customer in France, the transaction may fall within the rules for intra-Community distance sales. The business may be able to report the French VAT through its Union OSS return rather than obtaining a French VAT registration solely for that distance sale.

But there is an important distinction.

OSS deals with qualifying sales. It does not automatically remove a VAT registration created because your own goods are physically stored or transferred into another Member State under the current rules.

A business could therefore use OSS for certain B2C sales and still have a local VAT registration in the country where its warehouse stock is held.

Amazon FBA and fulfilment networks require extra attention

Businesses using Amazon FBA or another fulfilment provider should pay close attention to their stock reports.

The key question is not simply which marketplace generated the order. You need to know where the goods were physically located before the sale and whether stock was transferred between EU countries.

If your fulfilment arrangement permits inventory to be moved between warehouses in different Member States, those movements can have their own VAT consequences.

Before activating a cross-border fulfilment structure, check:

• which countries are authorised to hold your stock;
• where each shipment to a fulfilment centre starts and ends;
• whether your own goods can be moved between Member States;
• which local VAT registrations you already have;
• which sales are reported locally and which are reported through OSS;
• whether your accounting records match the marketplace or fulfilment reports.

A platform report is useful evidence and an important accounting source, but it does not replace the company’s own VAT obligations.

Call-off stock can change the result, but only under specific conditions

Not every movement of stock automatically follows the standard treatment described above.

One important exception is the EU call-off stock simplification. It can apply where goods are moved to another Member State for a specific, already identified VAT-registered customer who is expected to take ownership later.

This is different from placing products in a general warehouse and waiting to see who buys them.

The simplification has detailed conditions. Among other requirements, the intended customer must be identifiable in advance, specific records and VAT reporting are required, and the arrangement is subject to a 12-month time limit.

If the relevant conditions stop being satisfied, the normal transfer-of-own-goods rules may become applicable and local VAT registration may then need to be considered.

Call-off stock should therefore not be used as a general label for every warehouse arrangement.

A simple VAT check before moving stock can prevent a complicated correction later

Before sending goods to another EU country, map the transaction from beginning to end.

Do not start with the question, “Where is my company registered?” Start with these questions:

• Who owns the goods during the movement?
• From which country do they leave?
• In which country do they arrive?
• Will they remain there before being sold?
• Is the future customer already known?
• Will the customer be a business or a private individual?
• From which country will the final customer order be dispatched?

These answers often reveal the VAT position much more clearly than the sales invoice alone.

Waiting until several months of transactions have accumulated can make the situation harder. The business may then need to reconstruct stock movements, determine when an obligation arose and reconcile warehouse reports with invoices and accounting records.

EU VAT rules are also changing, so timing matters

This article reflects the VAT framework applicable in 2026. Businesses planning longer-term European warehouse structures should also be aware that the EU has adopted the VAT in the Digital Age package.

From 1 July 2028, major Single VAT Registration reforms are scheduled to take effect. These include a new special scheme for transfers of own goods designed to reduce situations in which businesses need separate VAT registrations in multiple Member States.

That future reform is important, but it should not be applied prematurely. A stock movement made under the rules currently in force must be assessed under the rules applicable at the time of that movement.

Review the warehouse before the first shipment, not after the first VAT problem

Expanding your logistics network can make commercial sense. A warehouse closer to customers can improve delivery times and simplify fulfilment. But the VAT consequences need to be reviewed alongside the logistics plan.

A Bulgarian VAT registration does not mean that every stock movement and sale elsewhere in the EU can be reported only in Bulgaria. The country where the goods are physically located can be decisive.

Before sending inventory to Germany or another EU Member State, identify the stock flow, customer type and planned sales routes. Determine whether local VAT registration, local VAT returns or OSS reporting may be required.

For professional accounting and VAT support in Bulgaria, visit Accounting Services Bulgaria .

This article provides general information and does not constitute individual tax, accounting or legal advice. VAT treatment depends on the specific facts, the countries involved and the rules applicable at the time of each transaction. Each case should be reviewed individually before implementation.