Amazon FBA VAT: Seller Obligations in France
The FBA program is a cash machine for many e-commerce sellers. But it's also a nest of tax problems if you don't master your VAT obligations.
Introduction
The FBA (Fulfillment by Amazon) program is a cash machine for many e-commerce sellers. But it's also a nest of tax problems if you don't master your VAT obligations. Here's how to see clearly.
Three separate topics
How FBA Works and Its VAT Implications
With FBA, you send your products to Amazon warehouses which then handles logistics (storage, preparation, shipping, customer service). This model has major VAT consequences:
The Basic Principle
- Storage location = VAT registration obligation: as soon as your products are stored in a country, you must be VAT registered there, even if you don't sell directly there
- Stock transfer = Taxable operation: when Amazon moves your products from one warehouse to another, it's an intra-community operation
Concrete Example
You are a French seller. You send 1,000 products to the FBA warehouse in Lauwin-Planque (France). Amazon decides to transfer 200 to its Rheinberg warehouse (Germany) to optimize delivery times.
Tax Consequence
The Multi-Country Storage Trap
This is trap number 1 for FBA sellers. When you activate the Pan-European FBA program or use EFN (European Fulfillment Network), Amazon can move your stock to several European countries without asking your permission.
Consequences
- Mandatory registration in each storage country
- Local VAT declarations to produce in each country
- Stock transfers to declare as intra-community operations
- Compliance costs that explode
Amazon FBA Storage Countries in Europe
| Country | Main Warehouses |
|---|---|
| France | Lauwin-Planque, Montélimar, Metz, Brétigny |
| Germany | Rheinberg, Bad Hersfeld, Graben, Werne |
| Italy | Castel San Giovanni, Torrazza Piemonte |
| Spain | San Fernando de Henares, Castellbisbal |
| Poland | Wrocław, Poznań |
| Czech Republic | DobrovĂz, Brno |
Concrete Example
You are a French seller who activates Pan-European FBA. Amazon stores your products in Germany, Poland, and Italy to optimize delivery times. You must now register for VAT in these 4 countries and produce local declarations.
Amazon as VAT Liable
Since July 2021, Amazon may be liable for VAT in your place on certain sales. This mechanism, known as the "deemed supplier" rule, does not apply to all your sales: it depends on your seller status — established in the EU or not — and on the type of sale.
The Two Cases Where the Mechanism Applies
- Distance sales of imported goods worth €150 or less to EU private customers
- Sales of goods already located in the EU to EU private customers, where the seller is not established in the EU
What This Means for an EU-established Seller
If you are established in the EU and sell goods already stored in the EU, the mechanism does not apply: you remain liable, through OSS or a local registration depending on the stock origin and the destination.
| Situation | Who Collects VAT? |
|---|---|
| EU-established seller, EU stock, EU private customer | You (OSS or local registration) |
| Non-EU-established seller, EU stock, EU private customer | Amazon (deemed supplier) |
| Imported goods €150 or less, EU private customer | Amazon (deemed supplier) |
| B2B sale (customer with a valid VAT number) | You |
The Amazon report decides, not the general rule
Your Declaration Obligations
As an Amazon FBA seller in France, you must produce several declarations:
In France
- CA3 declaration monthly or CA12 annual
- DEB (Declaration of Exchange of Goods) for intra-community movements > €460,000
- OSS declaration if you sell B2C in other EU countries
In Other Storage Countries
- Local VAT declarations (monthly or quarterly depending on country)
- Intrastat if applicable
- EC Sales List for intra-community B2B sales
Typical Calendar for Multi-Country FBA Seller
| Obligation | Frequency | Deadline |
|---|---|---|
| CA3 France | Monthly | 19-24 of following month |
| VAT Germany | Monthly | 10 of following month |
| VAT Italy | Quarterly | 16 of month following quarter |
| OSS | Quarterly | Last day of following month |
Amazon Reports to Use
Amazon provides several essential reports for your VAT compliance:
VAT Transaction Report
This is the most complete report. It contains:
- Detail of each sale with VAT collected
- Shipping and destination country
- Customer VAT number (if B2B)
- Applied VAT rate
- Indication if Amazon is liable
| Column | Use |
|---|---|
| transaction-type | Operation type (SALE, REFUND, FC_TRANSFER) |
| tax-collection-model | Who collects (MARKETPLACE or SELLER) |
| ship-from-country | Origin country (where stock was) |
| ship-to-country | Destination country |
| item-vat-rate | Applied VAT rate |
Stock Movement Report
Essential for tracking transfers between warehouses and declaring your intra-community operations. It shows:
- Movement date
- Origin and destination warehouse
- Quantity and value of transferred products
Refund Report
To correctly adjust your collected VAT. Refunds must be treated as credits and reduce your VAT due.
How to Access Reports
Seller Central > Reports > VAT Reports > Generate a report
Download reports
Access Seller Central and download the VAT Transaction Report
Identify collector
Filter lines where tax-collection-model = SELLER
Break down by country
Group sales by ship-from-country and ship-to-country
Declare
Report amounts in your respective VAT declarations
NomadVAT Tip
Conclusion
Amazon FBA offers unparalleled logistics, but VAT complexity is real. Between multi-country storage, stock transfers, and different liability regimes, it's easy to get lost.
The key: automate the import of your Amazon data and their processing by a dedicated VAT compliance solution. NomadVAT integrates natively with Amazon to import your reports and automatically generate your declarations.