From 1 July 2028, an online seller holding stock in several EU countries, through Amazon PAN-EU for example, can in principle operate with a single VAT registration in its own country. The transactions that require a foreign registration today are redirected through three routes: the extended One Stop Shop, a new return for the transfer of own goods, and a mandatory reverse charge for domestic B2B sales.

The result is fewer registrations, but not less work. The filing obligation shifts to your home country and becomes heavier there. Below we walk through what changes, which situations still require a local registration, and what that means for your filing calendar.

Route 1: domestic B2C sales through the extended OSS

The One Stop Shop already exists for cross-border B2C sales. From July 2028 it also covers domestic B2C sales made from stock held abroad. The OSS return stays quarterly and is filed from your own country.

Take a Dutch seller who sells to a German consumer from a German Amazon warehouse. Today that requires a German VAT registration and a German return. From July 2028 the sale simply goes into the OSS return filed from the Netherlands.

The OSS scope grows in other ways too. Goods supplied with installation or assembly can go through it, as can all B2C services provided in a country where you are not established. From 1 January 2027 cross-border supplies of gas, electricity, heating and cooling to consumers are added as well.

Route 2: stock movements through the new TOOG return

TOOG stands for Transfer of Own Goods. Moving your own stock from one EU country to another counts as a supply to yourself for VAT purposes, which is exactly why a registration in both countries is needed today. From July 2028 you report all those movements in a single monthly TOOG return in your own country.

If Amazon moves part of your stock from Germany to Poland, that movement appears in your monthly TOOG return instead of in a German and a Polish filing. A nil return is required for months without any movements, so the return comes back twelve times a year regardless of activity.

Two conditions are worth noting. The intra-Community acquisition in the country of arrival is exempt, so no VAT is payable on the movement itself. And the scheme cannot be used for goods that do not carry a full right of deduction in the country of arrival. Movements reported under the TOOG scheme are left out of the EC Sales List.

Route 3: domestic B2B through a mandatory reverse charge

Domestic B2B sales also stop being a reason to register, but they do not run through the OSS. Where the seller is not established and not VAT registered in the country of supply, and the buyer is VAT identified there, the VAT is compulsorily reverse charged to the buyer under article 194.

Sell from German stock to a German company with a German VAT number and the buyer declares the VAT in its own German return, where it is usually deducted straight away. You remit nothing anywhere and issue an invoice without VAT stating that the VAT has been reverse charged. Member States may extend the reverse charge to further situations involving non-established suppliers, so the exact scope can differ per country.

There is one reporting obligation left. The seller lists these reverse charged sales in the EC Sales List, in the Netherlands the Opgaaf ICP, filed from its home country. A purely German transaction therefore ends up in a Dutch ICP listing, which is how the German tax authority can check whether the buyer actually declared the VAT. New boxes are expected in the Dutch return and the ICP listing for this. The detailed rules follow in early 2027 in the Explanatory Notes of the European Commission.

Watch out for your input VAT

Neither the OSS nor the TOOG return allows you to reclaim input VAT. Local costs have to go through a separate refund procedure, and that procedure is considerably slower than a local return. If you incur substantial VAT in a country, keeping the registration there is often the more practical choice, even when the new rules would allow you to drop it.

What stays outside the new rules

Some transactions fit none of the three routes, and each one of them keeps a local registration alive. The most important is the cross-border B2B order shipped from foreign stock.

An order from a French company that Amazon ships from the German warehouse is an intra-Community supply from Germany. That transaction fits neither the OSS, nor the TOOG scheme, nor the reverse charge, so a German registration plus an ESL listing filed from Germany stays mandatory. Because Amazon decides which warehouse an order leaves from, a seller with Amazon Business switched on cannot deregister in the stock countries in practice, even when those orders make up only 1 to 5% of the total.

Other situations that keep a local registration in place:

• Imports into a country other than your country of establishment.
• Substantial local input VAT, where keeping the registration beats the refund procedure.
• Sales of margin scheme goods, which cannot be reported through the OSS.
• B2B sales to buyers without a local VAT number, since the reverse charge does not apply then.
• Goods without a full right of deduction in the country of arrival, which are excluded from the TOOG scheme.

What your filing calendar looks like before and after

The number of filings goes down, but the ones that remain get bigger and they all concentrate in your home country.

Other changes on the same date

The call-off stock simplification becomes redundant now that stock movements run through the TOOG scheme, so it is being phased out. No new call-off stock transfers can be made after 30 June 2028, and stock already transferred has to be delivered to the intended customer by 30 June 2029 at the latest. If you use the scheme today, plan the switch before those dates.

The 10,000 euro threshold for cross-border B2C sales is also clarified. Only sales dispatched from your own country of establishment count towards it, so goods shipped from stock in another EU country fall outside the calculation. Registering for the OSS means you are treated as having waived the threshold altogether.

The timeline in short

• 1 January 2027: minor OSS and IOSS changes, including energy supplies to consumers through the OSS.
• Early 2027: Explanatory Notes from the European Commission with the practical detail, followed by national implementation.
• 1 July 2028: extended OSS, TOOG scheme and mandatory reverse charge take effect. Call-off stock closes for new transfers.
• 30 June 2029: the transitional period for existing call-off stock ends.
• 1 July 2030: the ESL and ICP listing disappear and this reporting moves into digital reporting per transaction, the e-invoicing pillar of ViDA.

How to prepare

Start with your order mix per country. How much B2B do you actually ship from foreign stock, and how much of it crosses a border? That share decides whether a registration can go at all. Tied to this is a decision about Amazon Business: switching it off can free up registrations, and keeping it on means keeping them.

Next, get your stock movement data in order. The TOOG return runs on fulfilment and inventory reports from your marketplaces, so that data needs to be complete and reconcilable every month. Check your local input VAT per country as well, because substantial local costs are a reason to keep a registration regardless of the new rules. Finally, set your invoicing up for the reverse charge: domestic B2B invoices without VAT need the correct wording and a validated VAT number for the buyer.

Frequently asked questions

Is the new scheme mandatory?

No, the OSS and the TOOG scheme are optional. But if you opt in, every transaction in that category has to run through the scheme. You cannot use it in one country and file locally in another.

Can I cancel all my foreign registrations in July 2028?

Only if you sell purely B2C, import into your own country and have little local input VAT. Any B2B shipped from foreign stock, imports elsewhere or significant local costs will keep at least one registration in place.

Does the TOOG return have to be filed in quiet months too?

Yes. A nil return is required for every month without stock movements.

Does a stock movement still go into the ESL listing?

No. Movements reported under the TOOG scheme are left out of the ESL. Reverse charged domestic B2B sales do have to be listed there.

Does less admin mean less work?

Not really. The number of returns goes down, but they get bigger and they concentrate in your home country, fed by stock and order data from your marketplaces. Data quality becomes the deciding factor.

In short

Pure B2C sellers can cut back sharply on their foreign registrations from mid 2028. Anyone with even a little B2B, imports or substantial local costs will keep registrations. And the filing work does not disappear, it shifts: from 12 local returns per country to 4 larger OSS returns, 12 TOOG returns and a heavier domestic return plus ICP listing each year, all fed by data from your marketplaces.