Storing stock with Fulfilled by TikTok? Here's when you must register for VAT

What is Fulfilled by TikTok, and where is your stock held?

Fulfilled by TikTok is TikTok Shop's own logistics service: you send your inventory to a TikTok warehouse, and TikTok picks, packs and ships each order for you. It is the direct equivalent of Fulfilled by Amazon (FBA), and it carries the same VAT consequence. The physical location of your stock, not the platform you sell on, is what creates your tax obligations.

As of 2026, FBT stores seller inventory in three EU countries: Spain, Germany and the Netherlands. TikTok has signalled further warehouses in Poland, Belgium and Sweden, but availability changes fast, so treat any country outside the core three as “check current status” before you commit stock.

This matters because a single account can spread your stock across several of these warehouses. TikTok may split inventory to shorten delivery times, and it may move goods between sites. Each country where your stock sits is a country where you have a VAT footprint.

FBT and Amazon FBA: the same VAT logic

If you already sell through Amazon's Pan-European FBA programme, you know this pattern. Amazon moves your stock across its European network, and each storage country requires a local VAT number. FBT works the same way. There is no TikTok-specific exemption, no grace period tied to sales volume, and no way to “cover” foreign stock with a home-country registration.

Why storing stock abroad triggers a local VAT registration

The trigger is the holding of stock, not your sales figures. Under EU VAT law, a taxable person who holds goods in a Member State to supply them there has a taxable presence in that country. The chargeable event is physical, so a seller with €500 of stock in a German warehouse has the same registration duty as one with €500,000.

Two separate operations happen when you send goods to an FBT warehouse in another country, and both matter for VAT.

The first is the transfer of your own goods. When you move stock from one Member State to your warehouse in another, EU law treats that movement as a deemed intra-Community supply in the country of departure and a deemed intra-Community acquisition in the country of arrival, under Article 17(1) of Directive 2006/112/EC. You are, in effect, both the seller and the buyer of that transfer, and you report it in both countries.

The second is the local sale. Once the stock is in, say, Spain, a sale to a Spanish consumer is a domestic supply taxed in Spain, and a sale to a consumer in another Member State is an intra-EU distance sale taxed where the customer is (Article 33). The distance sale can run through OSS; the domestic sale and the stock transfer cannot.

Register before the goods arrive

You need the local VAT number before your first pallet reaches the warehouse. The registration attaches to the transfer of your own goods, and that transfer happens the day the stock crosses into the country, not the day you make your first sale. Registering afterwards means you have already run a taxable operation without a number, which is exactly what tax authorities look for.

The €10,000 OSS threshold does not exempt you

The Union OSS is a filing convenience for cross-border B2C distance sales, and nothing more. It lets you declare, in one return, the VAT due in every Member State where your customers live, so you avoid registering in each of them. It is genuinely useful. It is also frequently misunderstood as a blanket exemption, which it is not.

OSS covers one thing: distance sales of goods you ship from one country to consumers in another. It does not cover:

• goods you hold in local stock (the registration duty is separate and comes first);
• domestic sales, where the stock and the customer are in the same country;
• B2B sales;
• the transfer of your own goods between countries.

In practice, the €10,000 OSS threshold is the line below which a distance seller can keep charging home-country VAT instead of destination VAT. It applies to a business shipping from a single Member State. The moment you hold stock abroad, you are no longer that business, and the threshold is irrelevant to you. There is no equivalent small-seller allowance for holding foreign stock.

Who collects the VAT: you or TikTok? (deemed supplier, Article 14a)

For some sales, TikTok is treated as the deemed supplier and collects the VAT at checkout on your behalf. This is a real relief on collection, but it is not a relief on registration, and the distinction trips up almost everyone.

EU law creates two deemed-supplier situations under Article 14a:

• Article 14a(1): goods imported from outside the EU in consignments of €150 or less. Here the electronic interface is deemed to supply the goods, typically through the Import One-Stop Shop (IOSS).
• Article 14a(2): goods already located in the EU that are sold by a non-EU seller to an EU consumer. Here the platform is deemed supplier on that B2C sale, with no value cap.

If you are a non-EU seller — a non-established seller on TikTok Shop — storing stock in an FBT warehouse, your sales to EU consumers fall under Article 14a(2): TikTok charges and remits the VAT on those sales. That does not remove your own registration. You still moved your goods into the country (a transfer of own goods you must report), and you still hold local stock, so you still register locally.

If you are an EU-established seller, Article 14a(2) does not apply to you. TikTok is not your deemed supplier, and you collect and remit the VAT on your sales yourself, through your local registration and, where relevant, OSS.

Your VAT obligations by storage country

The core duty is the same everywhere: hold stock, register locally, before arrival. What changes country by country is whether you need a fiscal representative, and that depends on whether you are established in the EU. Never assume a fiscal representative is required everywhere. It is a country-by-country, status-by-status question.

Spain (Agencia Tributaria, AEAT)

Spain's standard VAT rate is 21%. An EU-established seller registers directly. A non-EU seller normally must appoint a fiscal representative in Spain, unless their country has a mutual-assistance agreement with the EU. Norway, the United Kingdom, the United States, Japan and Canada are among the countries covered by such agreements, so a seller established there can often register without a representative. Confirm your own country's position before you assume either way.

Germany (Finanzamt / BZSt)

Germany's standard VAT rate is 19%. Germany does not require a fiscal representative: every seller, EU or non-EU, registers directly with the competent Finanzamt. The German Fiskalvertreter exists only for businesses carrying out exclusively exempt activities, which is not your situation when you sell goods from stock.

The Netherlands (Belastingdienst)

The Dutch standard VAT rate is 21%. Registration is direct, and a fiscal representative is not required in principle. There is, however, a strong reason to consider one: the Article 23 import VAT deferment licence. It lets you defer import VAT to your VAT return instead of paying it at the border, which is a real cash-flow advantage if you also import into the Netherlands. Accessing the Article 23 licence as a non-established business generally means appointing a fiscal representative in the Netherlands. That is an option worth pricing, not an obligation.

A quick decision guide

Run your setup through four questions, in order, and the answer falls out:

1. Where will my stock physically sit? Every FBT country on that list is a country where you register locally, before the goods arrive. One warehouse, one registration; three warehouses, three.
2. Am I established in the EU or outside it? EU-established sellers register directly everywhere. Non-EU sellers add the fiscal-representative question, which bites in Spain but not in Germany or the Netherlands.
3. Where do my customers live? Same country as the stock means a domestic sale on your local return. Another Member State means an intra-EU distance sale, which you can declare through OSS on top of your local registration.
4. Who is the deemed supplier? If you are a non-EU seller, TikTok collects the VAT on the B2C sale under Article 14a(2). You still file for the stock and the transfer of your own goods. If you are EU-established, you collect and remit yourself.

The pattern holds whatever your turnover: the stock decides the registration, your establishment decides the representative, the customer decides the destination, and the platform decides only who hands the checkout VAT to the tax office.

Need help getting VAT-registered before you ship?

Registering in Spain, Germany or the Netherlands before your stock arrives, handling the fiscal-representative question where it applies, and keeping your OSS return aligned with your local filings is exactly the work we do every day. If you are about to activate Fulfilled by TikTok, we can map your registrations to your storage countries and put the numbers in place before the first pallet moves.

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