EU stock transfers from France: VAT rules for permanent and call-off stock

I'm Jim, VAT Specialist at Eurofiscalis. I help French and international companies secure their operations across Europe.

Permanent stock transfers from France

A permanent stock transfer occurs when a company moves goods from France to a warehouse, branch or depot it owns in another EU Member State. The final customer is not known at the time of dispatch. VAT rules in France determine how this movement is reported.

For French VAT purposes, the dispatch is treated as an exempt intra-Community supply. In the country of arrival, the same movement normally creates an intra-Community acquisition under local VAT rules. VAT in France sets the applicable French VAT rates.

• Issue a proforma invoice without VAT between the French VAT number and the VAT number in the destination country.
• Report the transfer on line F2 of the French CA3 VAT return.
• Declare the flow in ERTVA and EMEBI under regime 21-11.

Call-off stock and depot contracts

Call-off stock and depot contracts apply when the customer is already identified before the goods leave France, but ownership transfers later. The VAT treatment follows the timing of that ownership transfer.

• Issue a proforma invoice without VAT to the identified customer when the goods are physically moved.
• Keep a register of goods placed under call-off stock or depot arrangements.
• Report the physical movement in the VAT recapitulative statement under regime 20.

When the customer later withdraws the goods, the actual sale occurs. Each partial or total withdrawal must then be treated as an intra-Community supply from France.

• Issue the final invoice without VAT to the customer.
• Report the sale on line F2 of the CA3.
• Declare the sale in ERTVA and EMEBI under regime 21-32.

After 12 months or if goods return to France

The 12-month period is the breaking point of the simplification. If the goods are not sold within that period, the supplier must register for VAT in the country where the stock is located and regularise the initial movement.

• Issue a proforma invoice between the French VAT number and the foreign VAT number.
• Report an intra-Community supply in France on CA3 line F2.
• Declare the flow in ERTVA and EMEBI under regime 21-11.
• Treat later sales from the stock as local sales in the storage country.

If goods return to France within 12 months and ownership never transferred, the initial reporting is corrected in ERTVA under regime 10. If the return occurs after 12 months, it is reported in EMEBI under regime 19 and in ERTVA under regime 25.

Secure CA3, ERTVA and EMEBI before shipping

The correct treatment is decided before the truck leaves. Identify the flow, the customer, the owner of the goods at dispatch and withdrawal, and the possible local VAT registration before month-end reporting on VAT return in France, ERTVA and Intrastat in France.

• Classify the flow as permanent transfer, call-off stock or depot contract.
• Confirm who owns the goods at dispatch and at withdrawal.
• Choose the correct CA3 line, ERTVA regime and EMEBI regime.
• Keep the proforma invoice, final invoice and stock register.

Eurofiscalis can review your French stock-transfer flows and prepare the reporting logic for CA3, ERTVA and EMEBI before deadlines.