Consignment stock in Germany: can a UK company use it?
No. Not under § 6b UStG, because the call-off stock simplification only covers movements between two EU member states, and the United Kingdom is a third country after Brexit. Goods sent from Great Britain into a German warehouse are an import, and holding stock in Germany requires a German VAT registration from the first unit.
Three facts decide this.
Where the goods start: § 6b UStG runs member state to member state, so an Irish, Dutch or Polish supplier can use it and a British one cannot. Whether one buyer is already known: the rule needs a named buyer with a full address before transport begins, which is why Amazon FBA and third-party logistics stock never qualifies. How long the goods sit there: twelve months, after which the movement becomes a deemed transfer and a German registration obligation.
Can a UK company use the German call-off stock rule after Brexit?
No. The call-off stock simplification in § 6b of the German VAT Act (Umsatzsteuergesetz, UStG) is written for goods moving from the territory of one EU member state into the territory of another. Since Brexit the United Kingdom is a third country, not a member state, so the provision cannot reach a movement that starts in Great Britain. Nothing here turns on who your customer is or how well you know them: the departure point alone puts you outside the rule. What applies instead is the ordinary third-country treatment. Goods arriving from Great Britain into a German warehouse are an import, so there is import VAT (Einfuhrumsatzsteuer) and customs at the border, an EORI number is needed to clear them, and stock physically held in Germany creates a German VAT registration obligation from the first unit, with no turnover threshold. An Irish, Dutch or Polish supplier faces none of that, because their movement stays inside the EU.
| Where your goods start | Can § 6b UStG apply? | What happens instead |
|---|---|---|
| Another EU member state (Ireland, the Netherlands, Poland, and so on) |
Yes, if all four conditions hold | At the moment of supply it is an exempt intra-community supply where the goods started and an intra-community acquisition by your buyer in Germany. No German registration for you. |
| Great Britain | No | A third country, not a member state. The arrival is an import: import VAT and customs at the border, an EORI number to clear the goods, and a German VAT registration from the first unit. |
| Any other third country (United States, China, Switzerland, Norway, Turkey) |
No | Same position as Great Britain. § 6b UStG names member states only, so the movement is an import and the German registration obligation follows the stock. |
Being VAT-registered somewhere in the EU does not move your goods. The test in § 6b(1) UStG looks at the territory the transport starts from, not at which VAT numbers you hold.
What are the four conditions in § 6b UStG?
The simplification is not automatic for EU suppliers either. All four conditions in § 6b(1) UStG have to hold at once, and losing any one of them ends the arrangement. First, the goods move from the territory of one member state to the territory of another so that a supply can be made to a buyer after they arrive, under an agreement that already exists, and that buyer's full name and full address are known to you at the moment transport begins. Second, you have no seat, place of management, fixed establishment, residence or habitual abode in the destination member state. Third, the buyer has given you the VAT identification number issued by the destination member state, before transport begins. Fourth, you keep the separate register required by § 22(4f) UStG and file the EC Sales List (Zusammenfassende Meldung, § 18a UStG) correctly and on time.
Where all four hold and the supply happens in time, § 6b(2) UStG treats the transaction at the moment of supply as an exempt intra-community supply in the departure state and an intra-community acquisition by the buyer in the destination state. That is the whole benefit: the supplier does not register for VAT in the destination state.
- Known buyer: full name and full address, under an existing agreement, before transport begins.
- No presence: no seat, management, fixed establishment, residence or habitual abode in the destination state.
- Their VAT ID first: issued by the destination state, given to you before transport begins.
- Records and reporting: the separate register under § 22(4f) UStG plus a correct, timely EC Sales List under § 18a UStG.
What happens if the goods are not supplied within twelve months?
The twelve-month clock is the part that catches people out. Under § 6b(3) UStG, if the supply to the buyer is not made within twelve months of the end of the transport, and none of the situations in § 6b(6) UStG applies, then on the day after those twelve months expire the movement counts as a deemed intra-community transfer (innergemeinschaftliches Verbringen). A transfer is your own movement of your own goods with no buyer on the other side, and it is exactly the event the simplification existed to avoid: it creates a VAT registration obligation for you in the destination state. Nothing has to go wrong for this to happen. A buyer who simply draws down more slowly than planned, on a batch that arrived thirteen months ago, is enough. If you run consignment stock in Germany under § 6b UStG, the arrival date of every batch belongs in a system, not in somebody's memory.
If the goods are not supplied to the buyer within twelve months of arriving, the movement becomes a deemed intra-community transfer on the day after, and that transfer carries a registration obligation in the destination state.
§ 6b Abs. 3 UStG„Wird die Lieferung an den Erwerber nicht innerhalb von zwölf Monaten nach dem Ende der Beförderung oder Versendung des Gegenstandes im Sinne des Absatzes 1 Nummer 1 bewirkt und ist keine der Voraussetzungen des Absatzes 6 erfüllt, so gilt am Tag nach Ablauf des Zeitraums von zwölf Monaten die Beförderung oder Versendung des Gegenstandes als das einer innergemeinschaftlichen Lieferung gleichgestellte Verbringen (§ 6a Absatz 2 in Verbindung mit § 3 Absatz 1a).“
§ 6b Abs. 3 UStG, Konsignationslagerregelung
Can you send the goods back, or swap the buyer?
Yes to both, within the twelve months, and each route has to be recorded. § 6b(4) UStG covers the return: if the goods go back to the departure member state inside the twelve months and the return is recorded in your register, the deemed transfer does not happen. § 6b(5) UStG covers the substitution: the buyer named at the start may be replaced by another business inside the same window, provided the new buyer has supplied a VAT identification number issued by the destination member state and the change is recorded. § 6b(6) UStG is the other side of the coin. If any condition falls away, the deemed transfer happens on that day rather than at the twelve-month mark, and the same applies if the goods move on to a different member state or leave for a third country. Where goods are destroyed, lost or stolen, the conditions end on the day that is established.
In every one of these cases the register under § 22(4f) UStG is what shows which case you are in. A German tax office (Finanzamt) reviewing a call-off arrangement is reading that register, so an arrangement you cannot evidence is an arrangement you do not have.
Is Amazon FBA or 3PL stock the same as call-off stock?
No, and this is the most common confusion on the topic. Call-off stock under § 6b UStG means goods sent for one known buyer, named and addressed before transport starts, under an agreement that already exists. Amazon FBA inventory is the opposite of that: it sits in a fulfilment centre waiting for orders from consumers nobody has identified yet, and Amazon is not the buyer. Stock held by a third-party logistics provider for general order fulfilment is in the same position, and so is stock you move into Germany simply to shorten delivery times. Because there is no known buyer at the moment transport begins, the first condition of § 6b(1) UStG fails, and with it the whole simplification. What remains is the ordinary rule for stock held in Germany: a German VAT registration from the first unit, with no turnover threshold, whatever country the seller sits in. Our page for Amazon FBA sellers works through that setup in detail.
What does a UK company have to do instead?
Register in Germany, and treat the border and the VAT number as two separate jobs. On the customs side, an EU EORI number is needed to bring goods in and import VAT is payable at the border. Customs clearance and importer-of-record questions are not ours and we do not advise on them. On the VAT side, holding stock in Germany means a German VAT registration and monthly returns (UStVA), plus the annual return (Jahreserklärung), from the first unit onwards. That part is what we run. If you already hold a German tax number (Steuernummer), the filing plan is €89 per month or €990 per year and covers your monthly and annual returns. If you still need the registration itself, the all-in plan is €1,299 per year, charged in full at signup, covering the German VAT registration plus every filing for the year. Both are on our pricing page, and the post-Brexit specifics are on our page for UK companies.
You still do your part each period: you enter your figures or upload your report, and we prepare the return, review it and file it with the tax office (Finanzamt).
If a German letter has already arrived
Stock that sat in Germany before anyone registered usually surfaces as a letter rather than a question. If you are holding a German letter you cannot read, our Finanzamt letter reader tells you what it says and what the deadline is, free, before you decide anything.
Stock in Germany, handled from the registration onward.
Vaytax runs German VAT for foreign companies: the registration where you need one, the monthly and annual returns, and the Finanzamt correspondence that goes with them. €1,299 per year all-in including the German registration, or €89 per month if you already have a Steuernummer.
Start the registration Licensed German tax advisor · English throughout · No calls requiredAsked about consignment stock
It has to register for German VAT and account for its German supplies under that registration. The § 6b UStG call-off stock simplification, which is the rule that lets a supplier avoid registering in the destination country, only covers movements between two EU member states, and the United Kingdom is a third country after Brexit. Goods sent from Great Britain into a German warehouse are an import: import VAT and customs at the border, an EORI number to clear them, and a German VAT registration from the first unit with no turnover threshold.
No. § 6b UStG applies to goods moving from the territory of one EU member state to the territory of another. After Brexit the United Kingdom is a third country, not a member state, so a movement starting in Great Britain is outside the provision no matter how well the buyer is known. An Irish, Dutch or Polish supplier can use it, provided all four conditions in § 6b(1) UStG are met.
If the supply to the buyer is not made within twelve months of the goods arriving, then on the day after those twelve months the movement counts as a deemed intra-community transfer (§ 6b(3) UStG). A transfer creates a VAT registration obligation in the destination state, which is exactly what the simplification was meant to avoid. Sending the goods back to the departure state within the twelve months, or substituting another business that supplies a destination-state VAT identification number, prevents it, provided the change is recorded.
No. Call-off stock means goods sent for one buyer whose full name and full address are known before transport begins. Amazon FBA inventory and general third-party logistics stock wait for orders from customers nobody has identified yet, so the first condition of § 6b(1) UStG fails and the simplification does not apply. Stock held in a German warehouse then requires a German VAT registration from the first unit, with no turnover threshold.
A supplier moving goods from another EU member state, with no seat, place of management, fixed establishment, residence or habitual abode in Germany, who knows the buyer's full name and full address before transport begins, has been given the German VAT identification number by that buyer before transport begins, keeps the separate register required by § 22(4f) UStG, and files the EC Sales List (Zusammenfassende Meldung) correctly and on time. All four conditions have to hold together.
Yes. The third condition of § 6b(1) UStG is that the buyer has given the supplier the VAT identification number issued by the destination member state before the transport or dispatch begins. If the number is only supplied afterwards, that condition is not met and the simplification is not available for that movement.
Sources & official references
- § 6b UStG: Konsignationslagerregelung
- § 22 UStG: Aufzeichnungspflichten (see Absatz 4f)
- § 18a UStG: Zusammenfassende Meldung
- Umsatzsteuergesetz (UStG), full text
General information on German VAT, current as of July 2026. Not individual tax advice for your company, and not customs or import advice.