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What the OSS is today, and why it falls short
The One-Stop Shop (OSS) is a portal that lets a seller declare and pay, through one single Member State, the VAT due on B2C sales made anywhere in the European Union. It removes the need to register in every country where your customers live. Since 2021 it has covered intra-EU distance sales of B2C goods, with a single 10,000 EUR threshold above which VAT falls due in the country of consumption.
That threshold does not move with the reform. What matters is what the OSS does not cover today. The OSS handles cross-border sales, the ones where goods leave one country to reach a customer sitting in another. It ignores local sales: when you sell to a German customer out of stock already located in Germany, that is a domestic supply. It is taxable from the very first euro in the country where the stock sits, and it triggers a local VAT registration.
This is exactly the wall that every seller storing goods in several countries runs into. The current portal is not going away, so it stays the building block the reform is constructed on. If you are not enrolled yet, getting into the OSS now is still the right first move.
What multi-country stock really forces on you (the Amazon FBA case)
A seller on the Amazon Pan-EU programme hands stock over to Amazon, which spreads it across its warehouses to match demand. The concrete result: your products can sit at the same time in Germany, Poland, Italy, Spain, the Czech Republic and France. Every country of storage triggers two obligations.
First obligation: a local VAT registration in each country where your goods are stored, because the moment stock is present there, domestic sales become possible. Second obligation: every movement of your goods from one warehouse to another is a deemed transfer of own goods, treated as an intra-Community supply in the country of departure and an intra-Community acquisition in the country of arrival. You have to report those movements, even though you are effectively selling to yourself.
An active Pan-EU seller therefore ends up with five to nine VAT numbers, that many periodic returns, recapitulative statements and Intrastat thresholds to monitor. It is heavy, expensive, and a breeding ground for mistakes.
What ViDA changes on 1 July 2028: the expanded OSS
From 1 July 2028, the OSS widens its scope. It does not replace the current system, it extends it. This is the third pillar of the ViDA reform (VAT in the Digital Age), adopted by the Council of the European Union on 11 March 2025 through Directive (EU) 2025/516.
The expanded OSS will now cover:
- domestic B2C supplies of goods made by a seller not established in the country of consumption, precisely the blind spot described above;
- all B2C services supplied by a non-established operator;
- installation and assembly work delivered to private individuals;
- sales of goods on board ships, aircraft and trains.
For e-commerce, the extension to a non-established seller's domestic B2C sales is the real turning point. A seller clearing German stock to German customers will be able, under conditions, to declare that VAT through the OSS instead of a local registration. One scheduling note: the OSS opens up to gas, electricity, heating and cooling supplied to private individuals as early as 1 January 2027, a year before the main package.
The transfer of own goods scheme: the real stock game-changer
The transfer of own goods is a new special OSS scheme, created by Articles 369xa to 369xk of the VAT Directive (with the technical detail set out in Implementing Regulation (EU) 2026/1869), applicable from 1 July 2028. It concerns the movements of a business's goods to itself across the Union, exactly the inter-warehouse shuffles of an FBA seller.
The principle is simple. Instead of reporting each transfer as a deemed intra-Community supply in one country and an acquisition in the other, with the registrations that come with it, you record all your intra-EU stock movements on a dedicated monthly OSS return. The transfer and the matching intra-Community acquisition are exempt, which keeps VAT neutral. Those movements also drop out of the recapitulative statements.
The effect is direct: you no longer need to register in a country for the sole reason that you store your own goods there.
The condition you cannot miss: a full right to deduct
The scheme is optional, but conditional. It is only available if you hold a full right to deduct in the Member State where the stock arrives. Capital goods, and more broadly any goods that do not open a full deduction in the country of arrival, are excluded from the scheme.
In plain terms: if you have input VAT to recover in the country of arrival, or only a partial right to deduct there, the transfer of own goods scheme does not apply and a local registration becomes necessary again. This technical point is what separates the clean files from the ones that demand a proper analysis.
Amazon FBA Pan-EU: the picture before and after 2028
The table below sums up the shift for an FBA seller storing in six countries.
| Item | Before 1 July 2028 | From 1 July 2028 |
|---|---|---|
| Local VAT registrations | One per country of storage (often 5 to 9) | Potentially a single one, under conditions |
| Inter-warehouse transfers | Deemed supplies and acquisitions reported locally | Single monthly OSS return (transfer exempt) |
| Cross-border B2C sales | Union OSS (already in place) | Union OSS (unchanged) |
| Domestic B2C sales from local stock | Local registration mandatory | Expanded OSS, for a non-established seller |
| Local B2B sales | Registration or reverse charge depending on the country | Generalised reverse charge (Article 194) |
| Call-off stock | Simplification available | Scheme removed (see below) |
The reading is clear: the reform attacks the two biggest pain points of the FBA model, the stock and the non-established seller's domestic sales. To handle your Amazon flows under today's rules, our dedicated guide explains how to declare your Amazon FBA sales through the OSS within the current framework.
The end of call-off stock: what to anticipate
The call-off stock simplification is disappearing. No new arrangement can be started after 30 June 2028. Arrangements running on that date keep producing their effects until 30 June 2029, the point at which the scheme is fully extinguished.
This simplification let you transfer stock to a customer identified in advance without an immediate registration in the country of arrival. The new transfer of own goods scheme takes over, with a different logic and a wider scope.
Do you still need a VAT registration in 2028?
Yes, in several cases. The reform sharply cuts the number of registrations, it does not abolish them. Here is the decision grid I apply with my clients.
You can aim for a single registration when: your sales are B2C, your stock moves between EU warehouses, and you hold a full right to deduct in the countries of arrival. In that scenario, the expanded OSS and the transfer of own goods scheme cover the essentials.
You must keep or take a local registration when: you import goods into a country (the importer needs a local VAT number and, in most cases, an EORI number), your right to deduct in the country of arrival is not full, or you carry out operations outside the OSS scope.
For B2B, the logic is different. From 1 July 2028, the reverse charge becomes mandatory across all 27 Member States when the supplier is non-established and not identified and the customer is identified for local VAT. The customer accounts for the VAT, and the supplier no longer has to register for that flow. This mechanism obeys precise cumulative conditions, which we break down in the FAQ below.
Need help preparing for the 2028 OSS reform?
ViDA simplifies e-commerce VAT, but only if you pin down precisely which flows the expanded OSS and the transfer of own goods scheme absorb, and which ones keep a local registration. Our specialists map your stock and your sales country by country, then size your compliance for 2028.
FAQ
Does the OSS cover my Amazon stock spread across several countries?
Not today. Each country of storage forces a local registration and the reporting of inter-warehouse transfers. From 1 July 2028, the transfer of own goods scheme will let you report those movements through a single monthly OSS return, provided you hold a full right to deduct in the country of arrival.
What is the transfer of own goods scheme in VAT?
It is a special OSS scheme, applicable from 1 July 2028, that covers the movements of a business's goods to itself across the Union. The transfer and the matching intra-Community acquisition are exempt, and the business no longer has to register locally for the sole purpose of storing its goods there.
Do I still need a local VAT number in 2028?
Yes, in several cases: to import goods into a country, when your right to deduct there is not full, or for operations outside the OSS scope. The reform cuts the number of registrations sharply without removing them all. A tax representative in France or in your target country secures these residual cases.
Is call-off stock really disappearing?
Yes. No new call-off stock arrangement can be started after 30 June 2028, and the scheme is fully extinguished on 30 June 2029. The transfer of own goods scheme replaces it with a wider scope. An audit of your stock before mid-2028 is strongly recommended.
What is the difference between OSS, IOSS and local registration?
The OSS declares the VAT on intra-EU B2C sales through a single portal. The IOSS covers low-value B2C imports, up to 150 EUR. A local registration stays necessary for imports, for recovering input VAT, and for operations outside the OSS. The three complement each other, they do not substitute for one another.
Does the OSS cover B2B sales?
No. The OSS targets sales to private individuals (B2C). For intra-Community B2B, the reverse charge applies, and it becomes mandatory for non-established suppliers on 1 July 2028. This is the reverse charge under Article 194, which deserves its own detailed reading.
Does the 10,000 EUR threshold change with the reform?
No. The single 10,000 EUR threshold for intra-EU B2C distance sales stays in force. Below it, you apply the VAT of your own country. Above it, VAT falls due in the country of consumption and is declared through the OSS. This threshold does not apply to domestic sales from local stock.
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