Die EU-Umsatzsteuerreform 2021 und der One-Stop-Shop für Amazon-Seller
The existing VAT regulations were designed for businesses from the 1980s-1990s, not for modern e-commerce. This creates challenges for Amazon sellers who quickly become liable in foreign countries when Amazon stores inventory abroad or when delivery thresholds are exceeded.
What the 2021 VAT Reform Accomplishes
A major VAT reform planned for 2021 aims to establish a "One-Stop-Shop" system. Sellers would file all foreign sales through their home country's tax office, eliminating the need for separate foreign tax numbers. The reform intends to replace current delivery thresholds with a single European threshold of €10,000.
Timeline for Implementation
Originally scheduled for January 1, 2021, the reform was delayed by approximately six months due to COVID-19. Germany and the Netherlands requested further postponement. Implementation was expected mid-2021, though confusion arose when some tax authorities sent outdated communications claiming immediate threshold elimination.
Impact on Amazon Sellers
The new regulations haven't yet been adapted for Amazon-specific services. Sellers using FBA with foreign warehouses or PAN-EU structures cannot use the One-Stop-Shop and must maintain foreign tax registrations. The legislation thus lags behind modern business practices.
Steuerpflicht und Lieferschwellenverzicht bei Amazons Erweiterung des Logistiknetzwerks (Programm Mitteleuropa)
Program Overview
The Central European Program allows Amazon to store and ship inventory from Poland and Czechia alongside German fulfillment centers. Participating sellers receive a €0.50 shipping discount per item—regardless of actual shipment origin.
Foreign Tax Liability
Storing inventory abroad triggers immediate tax liability in that country, beginning with the first sale and independent of delivery thresholds. Sellers must register for tax numbers in Poland and Czechia before enabling this program in Seller Central.
Preparation Requirements
Obtaining foreign tax numbers requires 2-3 months, as applications route to local tax authorities. Additionally, sellers should request a "delivery threshold waiver" (Lieferschwellenverzicht) to avoid paying higher Polish (23%) or Czech (21%) VAT instead of German VAT (19%). This waiver involves a 30-day waiting period.
Cost-Benefit Analysis
The program becomes profitable around 500-600 FBA sales monthly, according to tax specialists. Sellers should calculate administrative costs against the €0.50 per-unit savings.
Ongoing Obligations
Tax registration doesn't automatically expire. Even if the program is deactivated in Seller Central, reporting obligations continue through year-end. Formal deregistration—involving fees and processing time—is required to fully cease obligations.
Umsatzsteuermeldepflicht im Ausland: Wann ist ein Amazon-Seller umsatzsteuerpflichtig?
Liability for Foreign Storage Without Sales
Mere warehousing without direct sales (like Amazon's Slovak return center) doesn't trigger tax liability. However, sellers must monitor warehouse locations regularly, as Amazon occasionally routes inventory to non-activated facilities.
Hidden Storage Risks
Sellers bear responsibility for tracking inventory locations. Failing to notice goods stored in unintended countries can result in unwitting tax liability and potential account suspension, particularly in jurisdictions with marketplace liability rules.
Marketplace Liability (Marktplatzhaftung)
Amazon assumes liability for unpaid VAT in certain countries, requiring sellers to provide VAT identification numbers (not just general tax IDs). Germany pioneered this rule; France followed in recent years, and Austria will implement it soon.
Umsatzsteuer im Ausland: Welche Strafen drohen bei Verstößen?
Penalty Structure
Penalties vary significantly by country and violation severity. Italy has imposed penalties of 230% of owed VAT in extreme cases—beyond the original debt itself.
Recent Developments
Poland now requires "SAF-T" (Standard Audit File Text) filings beyond standard VAT returns. Non-compliance theoretically allows €100 (500 Polish zloty) fines per unreported transaction, creating potential existential risks for large operations.
Corrective Actions
If errors occur, sellers should:
- Register retroactively in affected countries, specifying the threshold-crossing date
- Resubmit returns with correct VAT amounts
- Process refunds for overpayment in home countries
This process requires effort but prevents severe penalties.
Die Zukunft von Amazon in der EU: Expansion, neue Marktplätze und Steuern
European Expansion Strategy
Amazon added the Netherlands marketplace in March 2021 and plans warehouse expansion. Future marketplace additions include Scandinavia, particularly Sweden.
Scandinavian Opportunities and Challenges
Northern European markets are digitally mature with strong e-commerce sectors. However, most German sellers lack Scandinavian tax registration. Close monitoring of fulfillment infrastructure development is essential.
Typical Expansion Pattern
Amazon usually launches a marketplace before establishing FBA infrastructure, initially shipping from other countries. This occurred with Amazon.nl, where sellers anticipate upcoming Dutch warehouse facilities.
Seller Vigilance Requirements
Sellers must track delivery thresholds carefully, especially for new marketplaces requiring cross-border shipping. Multichannel sellers must aggregate sales across all platforms and countries.
Amazon doesn't always announce warehouse additions beforehand. New facilities can trigger unexpected tax liability. Tools like Taxdoo help track warehouse locations and tax obligations across jurisdictions.