Amazon EU programmes explained: EFN, Pan-EU and CEE
Amazon offers European sellers three main fulfilment programmes, each with a distinct logistics model — and consequently, distinct VAT consequences. Understanding which programme you use is the essential first step before determining your VAT strategy.
EFN (European Fulfilment Network) is the simplest model. Your inventory is stored in a single European Amazon fulfilment center — for example in the Netherlands or Germany — and Amazon ships orders from that one location to customers across Europe. The VAT advantage is clear: you only need a VAT registration in the storage country. The trade-off is longer delivery times for customers far from your warehouse and typically higher per-order shipping costs.
Pan-EU FBA (Pan-European Fulfilment by Amazon) is the most advanced model. Amazon automatically distributes your inventory across fulfilment centers in multiple EU countries — typically Germany, France, Italy, Spain, Poland and potentially the Czech Republic and Slovakia. This delivers faster shipping and lower fulfilment costs, but it creates fiscal nexus in every country where your inventory is held. You are therefore legally obligated to hold a VAT number in each of those countries.
CEE (Central Europe Programme) is a variant of Pan-EU specifically targeting Central Europe. Your inventory is stored in Poland, Czech Republic and/or Slovakia, from where Amazon ships to customers in Central and Eastern Europe. This programme can be attractive for sellers targeting these growing markets, but requires VAT registrations in PL, CZ and SK.
To check which programme you are using: log into Amazon Seller Central, navigate to 'FBA' and then 'FBA Settings' or 'Inventory Management'. Under the 'Tax' or 'Pan-European FBA' tab you can see which countries currently hold your inventory. This is your starting point for VAT analysis.
When do you need VAT registration in multiple EU countries?
The core principle of Amazon VAT is nexus: the moment your goods are physically present in a country — stored in an Amazon fulfilment center — you have a fiscal presence there and are required to register for VAT.
For Pan-EU, the mandatory registration countries are at minimum: Germany (DE), France (FR), Italy (IT), Spain (ES) and Poland (PL). If you also use the CEE programme, Czech Republic (CZ) and Slovakia (SK) are added. In total, you are looking at 5 to 7 VAT registrations. Each country has its own registration procedure, language requirements and processing time — Germany (Finanzamt) typically takes 4 to 8 weeks, Italy (Agenzia delle Entrate) can take up to 12 weeks.
For EFN, the situation is simpler: you need a VAT number only in the country where your inventory is stored. However, be aware that if your annual sales to consumers in other EU countries exceed the combined EU threshold of €10,000 (introduced with the 2021 OSS reform), additional registration obligations or OSS enrolment may arise.
What many sellers overlook is that registration requirements also apply to internal stock transfers. When Amazon moves your goods from one fulfilment center to another — for instance from Germany to Poland — this is fiscally treated as an intra-Community transfer of own goods. This must be reported in both countries and is precisely why OSS alone is insufficient for Pan-EU sellers.
VAT registration by country: step by step
Obtaining VAT numbers in multiple EU countries is a bureaucratic but necessary process. The approach differs by country, but the overall steps are consistent.
Step 1 — Identify your required countries: Based on your Amazon programme (see section 1), compile a list of countries requiring registration. Download the FBA inventory report in Seller Central and check which countries currently hold your inventory.
Step 2 — Choose your approach: You can appoint a local fiscal representative per country (required in some countries such as Italy for non-EU established sellers) or engage a specialist VAT service provider such as Taxdoo, Avalara, hellotax or Global-e.
Step 3 — Prepare documentation: Each country requires similar documents: company registration certificate (translated and legalised where required), passport or ID of directors, bank details and sometimes proof of business activity in the country.
Step 4 — Submit the application: Via the relevant country's tax authority or through your fiscal representative. Typical processing times: DE (Finanzamt) 4–8 weeks, FR (DGFIP) 4–6 weeks, IT (Agenzia delle Entrate) 6–12 weeks, ES (AEAT) 2–4 weeks, PL (US) 2–4 weeks.
Step 5 — Enter VAT numbers in Amazon Seller Central: Once received, enter your VAT numbers under 'Tax > VAT Numbers' in Seller Central. Amazon uses these in VCS and for automatic invoicing to consumers.
Step 6 — Set up your VAT filing calendar: Each country has its own filing frequency (monthly, quarterly or annual) and deadlines. Use a central calendar or automate this through your accounting integration.
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Invoice requirements for Amazon EU sellers
As an Amazon seller you deal with two customer types: consumers (B2C) and businesses (B2B). Invoice requirements differ substantially between these categories.
B2C invoices must include at minimum: seller name and address, seller's VAT number (of the country of dispatch), buyer name and address, a unique sequential invoice number, invoice date, product description and quantity, unit price excluding VAT, the applicable VAT rate and VAT amount, and the total amount including VAT. Note that the VAT rate applied must correspond to the destination country of the buyer for cross-border sales.
B2B invoices are more complex. When a business buyer provides their VAT number at the point of ordering, the VAT treatment changes entirely. You apply the reverse charge mechanism: the invoice states 0% VAT, includes the buyer's VAT number, and carries the notation 'VAT reverse charge' (or the equivalent in the destination country's language). This is a legal requirement and Amazon VCS does not generate these invoices automatically in most cases.
Country-specific requirements: in Germany, the Finanzamt requires a continuous invoice numbering sequence per VAT number. In Italy, electronic invoicing via the SDI (Sistema di Interscambio) system is mandatory for B2B invoices and increasingly for B2C. In Poland, the KSeF (Krajowy System e-Faktur) system becomes mandatory for B2B in 2025–2026. Your invoicing software must support these country-specific requirements.
The European Commission's taxation portal and HMRC provide detailed guidance on invoice requirements for intra-EU supplies. Consult these alongside local advisors for each registration country.
Amazon VCS vs. own invoicing: which is better?
Amazon offers its own VAT Calculation Service (VCS) as a built-in solution for VAT calculation and invoice generation. It is tempting to assume VCS covers all your invoicing obligations, but the reality is more nuanced.
What VCS does: VCS automatically calculates the correct VAT for B2C orders based on the buyer's destination country and product type. It generates an invoice accessible to the buyer through their Amazon account. This works reasonably well for standard consumer purchases where no VAT number has been provided.
What VCS does not do: VCS does not generate compliant invoices for B2B buyers who have provided a VAT number — these require a reverse-charge invoice that you as the seller must issue. VCS also does not support all country-specific requirements, such as Italian SDI invoices or Polish KSeF. Additionally, you have limited control over your own invoice numbering sequence and branding with VCS.
When is VCS sufficient? If you sell exclusively B2C, in markets without special e-invoicing requirements, and have no accounting system that needs structured invoice data, VCS can function as a basic solution.
When do you need own invoicing software? As soon as you sell B2B, sell in Italy (SDI) or Poland (KSeF), hold multiple VAT numbers, want to automate your accounting integration, or simply want full control and auditability over your invoicing. Dedicated invoicing software integrated with Amazon provides greater accuracy, flexibility and compliance assurance.
OSS and Amazon: how do they work together?
The One Stop Shop (OSS) is an EU scheme that allows sellers to declare B2C sales to consumers across all EU countries through a single VAT return — filed with the tax authority in your home country, such as HMRC (UK sellers pre-Brexit) or the Dutch Belastingdienst. This sounds like the perfect solution for pan-European selling, but the interaction between OSS and Amazon is more complex than many sellers realise.
OSS does work for EFN: If you use EFN with inventory in one country, your sales to consumers in other EU countries are B2C distance sales that fall precisely within OSS scope. You declare the VAT via OSS in your home country and do not need to file separate VAT returns in the other EU countries for these sales.
OSS does not cover internal transfers in Pan-EU: This is the critical point where many sellers go wrong. When Amazon moves your inventory from Germany to Poland — a so-called intra-Community transfer of own goods — this is fiscally treated as a supply to yourself in Poland. This falls entirely outside OSS scope and requires a local Polish VAT number. OSS only covers sales to end consumers, not internal stock movements.
The correct combination: With Pan-EU, you use local VAT registrations for returns in each storage country (covering internal transfers and local sales from that country) alongside OSS for B2C sales to consumers in EU countries where you hold no inventory. This requires careful segregation of your sales data using Amazon's Business Report and Tax Report tools.
The European Commission has published extensive documentation on OSS and its interaction with marketplace sales. Consult this alongside your VAT adviser when setting up your compliance framework.
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Winkel Factuur connects directly with Amazon Seller Central and generates correct invoices for every EU country — B2C, B2B and reverse-charge. Accounting integration included.
ViDA 2026 impact for Amazon sellers
ViDA (VAT in the Digital Age) is a comprehensive EU VAT reform being phased in between 2024 and 2030. For Amazon sellers, the most relevant changes concern the expansion of deemed supplier rules and the introduction of real-time digital reporting.
Deemed Supplier expansion: From 2025 onward, and progressively through 2028, marketplaces such as Amazon are increasingly designated as the legal supplier for VAT purposes on B2C transactions. This means Amazon itself becomes responsible for calculating and remitting VAT on your sales — not you. For individual sellers, this significantly reduces compliance burden: fewer VAT filings, less risk of errors, and reduced exposure to foreign tax authority audits.
What remains your responsibility: Even under ViDA, the seller remains responsible for providing accurate product data, VAT classifications (standard versus reduced rate) and business customer information to Amazon. Incorrect data results in Amazon calculating the wrong VAT, with potential assessments for the seller. Furthermore, ViDA does not cover B2B transactions: where a business buyer provides a VAT number, the reverse-charge obligation remains with the seller.
Digital Reporting (ViDA Pillar 2): ViDA also introduces real-time digital reporting requirements for intra-Community transactions, replacing the current EC Sales List and Intrastat reporting. Sellers active across the EU will need to adapt their systems to the new XML-based reporting standard, which integrates directly with national tax authority systems.
The forthcoming changes make it prudent to invest now in future-proof invoicing and accounting systems. Software that supports ViDA-compliant reporting and can receive updates as the legislation is progressively implemented will save significant effort and cost.
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Manually tracking VAT obligations across 5 to 7 European countries, creating the correct invoice type for each buyer, and meeting country-specific e-invoicing requirements is a significant operational burden. Winkel Factuur automates this process entirely.
Automatic B2B/B2C detection: Winkel Factuur reads your Amazon order stream and automatically detects whether a buyer has provided a VAT number. For B2C orders, the software applies the correct VAT rate for the destination country. For B2B orders, it generates a compliant reverse-charge invoice with all required notations.
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Accounting integrations: Winkel Factuur integrates directly with Exact Online, AFAS and Twinfield. Invoice data is automatically posted to the correct ledger account per country, with the correct VAT codes — making periodic VAT filing per country significantly simpler.
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