Pan-European FBA, EFN or MCI: what changes for your VAT
Where Amazon stores your goods decides how many countries you have to register for VAT in. The three programmes, compared.
In short
With the European Fulfilment Network (EFN), your stock is in a single country and Amazon ships from there to the others: these are distance sales through OSS, and the €10,000 threshold only helps you if that warehouse is in your own country. With Pan-European FBA or Multi-Country Inventory (MCI), your goods are stored in several countries: you need a VAT number in each one, and the threshold no longer applies.
The registrations and returns are yours: Amazon does not do them for you, unless you hire a separate service for it. Each stock transfer between countries is declared on both sides. If your business is from outside the EU, Amazon declares the VAT on your sales to consumers.
The three programmes, point by point
| EFN | Multi-Country Inventory (MCI) | Pan-European FBA | |
|---|---|---|---|
| Where your stock is | In a single country | In the countries you choose | Amazon spreads it across several countries |
| VAT number | Only in the country where the stock is, if it is not your own | In each country you send stock to | In each country where Amazon stores your stock |
| Sales to other countries | Distance sales through OSS; the €10,000 threshold only applies if the warehouse is in your country | Local when the order ships from the customer's country; if it ships from another, a distance sale through OSS | Local when the order ships from the customer's country; if it ships from another, a distance sale through OSS |
| Stock transfers | None if the warehouse is in your country; if it is in another, the initial shipment is a transfer | The ones you make | The ones Amazon makes, declared in the same way |
| Fulfilment fees | EFN fee for each order to another country | Local fees in each country | Local fees in each country |
What none of them changes
- EPR follows the customer's country, not the warehouse's: if you sell to German or French consumers, you need their packaging registrations in every case.
- Amazon fees come from Luxembourg: with ROI registration they arrive without VAT and you declare the Spanish VAT yourself under the reverse charge (if you are under the equivalence surcharge scheme, on Form 309).
- Amazon reports your sales every January to the Luxembourg tax authority, which passes them on to the Spanish Tax Agency (DAC7): what you declare has to match its reports.
Frequently asked questions
Does Pan-European FBA require me to register for VAT in several countries?
Yes: in each country where Amazon stores your goods, with the periodic returns and those for the transfers. Amazon does not do these registrations for you.
With EFN, do I need a VAT number in other countries?
Only in the country where your stock is, if it is not your own. Sales to customers in other countries are distance sales through OSS; the €10,000 threshold only counts if the warehouse is in your own country.
Can I start with EFN and later move to Pan-European FBA?
Yes. Before Amazon moves the first stock to another country you need its VAT number; it is advisable to apply in good time, because some countries take weeks.
Tell us where you sell
Book a 15-minute call or write to us. We tell you what you need to sell on each marketplace: registration, VAT on your sales and on the fees, OSS, EPR or whatever the platform has asked you for. No commitment.