As soon as you physically store your goods in a country, the OSS is no longer enough: this local stock requires a local VAT registration in each country of storage.
With Amazon's pan-European FBA, your stock is warehoused in several countries (Germany, Poland, Italy, Spain, the Czech Republic). The same logic applies to the United Kingdom, outside the EU since Brexit, which requires its own VAT GB number.
A Bulgarian company formed with Fenchell centralises all these numbers and returns under a single point of contact, from €125 excl. VAT per registration.
The scope of this guide. Here, we cover local stock: the case where your FBA goods are warehoused in several countries, which makes a local VAT registration mandatory — the OSS does not cover the physical presence of stock. This is not dropshipping. For distance sales shipped from a single country (the one-stop shop, thresholds, IOSS), refer to the pillar guide OSS / IOSS VAT for e-commerce.
Why is the OSS not enough with pan-European FBA?
When you launch an e-commerce business, you readily assume the European one-stop shop settles everything: one VAT number, one quarterly return, and the matter is closed. That is true as long as you ship everything from a single warehouse. The OSS / IOSS regime is precisely what lets you declare all intra-Community distance sales in a single place, without registering in each country of destination.
In practice, the OSS applies to cross-border B2C sales above a single pan-EU threshold of €10,000 in turnover; the IOSS, for its part, covers imports of goods in parcels with an intrinsic value not exceeding €150.
On the Bulgarian side, a company that crosses the VAT registration threshold — raised to €51,130 (≈ 100,000 BGN) of annual turnover since the reform of 1 January 2026 (чл. 96 ЗДДС, VAT Act, lex.bg) — obtains its BG number within 7 days, the starting point of the entire OSS and multi-country setup.
The removal of the under-€150 exemption announced for 1 July 2026 concerns customs duties (a temporary flat duty of €3/item until 2028), not VAT: the IOSS continues to collect B2C VAT on parcels ≤ €150. The proposal for mandatory IOSS for marketplaces was ultimately not retained in the VAT in the Digital Age (ViDA) package — it has been deferred to the 2028 customs reform (DG TAXUD, ViDA).
The problem arises as soon as the logistics grow more complex. Two very common situations among growing sellers shatter this comfort: storing goods abroad and selling in the United Kingdom. In both cases, the OSS no longer covers the transaction, and you shift to a logic of multiple VAT registrations.
The OSS handles distance sales flows, not the physical presence of stock. As soon as you own stock in a given country, that country requires a local VAT number, independently of the OSS.
Does FBA storage trigger local VAT obligations?
Amazon's pan-European FBA programme illustrates the trap perfectly. To cut delivery times and costs, Amazon automatically spreads your stock across several fulfilment centres — typically in Germany, Poland, the Czech Republic, France, Italy or Spain. Each warehouse that holds your goods creates a taxable local stock.
The consequence: you must obtain a standard VAT number in each country of storage, file the corresponding local returns, and continue in parallel to use the OSS for cross-border distance sales. Stock movements between warehouses (intra-Amazon transfers) are also transactions to be declared. You quickly see why a serious seller ends up with four, six, even eight active VAT numbers.
A cash-flow point often overlooked: the input VAT on your FBA fees (Amazon commissions, logistics, storage fees billed in a country where you are not registered) cannot be recovered via the OSS — the OSS declares only output VAT, never input VAT.
As an EU company (your Bulgarian EOOD is established within the Union), you recover it through the cross-border refund procedure of Directive 2008/9/EC: the claim is filed from the state of establishment (Bulgaria), electronically with the NRA, before 30 September of the following year (чл. 81 ЗДДС / Directive 2008/9/EC & Directive 2006/112/EC, art. 168).
This is one of the concrete advantages of starting from an EU base rather than a non-European one: an operator established outside the EU does not have access to this intra-Community mechanism.
| Situation | OSS enough? | Local number required? |
|---|---|---|
| Distance sales from 1 single country | No | |
| FBA storage in another EU country | Partially | Yes, per country |
| Intra-Community B2B sales | No (separate return) | Depending on the case |
| Sales / storage in the United Kingdom | No (outside the EU) | VAT GB |
For the physical movement of goods outside the EU, the EORI number also remains essential for customs clearance. Stock and customs are two distinct matters that must be handled together: once the EIK is obtained, the Bulgarian EORI activates in ≈ 3 working days (up to 5 in the event of a check) via the customs portal, after signing with your QES key.
Bulgaria does not have a general reverse charge on import VAT: for consumer goods imported from a third country (China, etc.), import VAT is paid at customs and then recovered on the next VAT return.
The deferred reverse charge provided for by чл. 167а ЗДДС (in force since 1 July 2019, lex.bg) is a restricted, self-assessed regime, reserved for certain raw materials in Annex 3, under cumulative conditions:
- value ≥ 50,000 BGN/item;
- VAT registration ≥ 6 months;
- no tax debt.
It does not apply to e-commerce or to standard FBA. Beware of promises of an "import cash-flow advantage" presented as a given: for an Amazon seller, they are inaccurate.
How do you handle VAT in the post-Brexit United Kingdom?
Since Brexit, the United Kingdom has left the European Union and, by extension, the scope of the OSS one-stop shop. No European VAT number covers your British operations. If you sell or store in the UK, four obligations stack up:
Obtained from the tax authority (HMRC). A seller not established in the UK is in principle entitled to no registration threshold and must register from its first taxable transaction. Official target time: ≈ 30 working days; in practice, more like 6 to 12 weeks.
A GB EORI separate from your European EORI for customs clearance — issued by HMRC immediately to within ≤ 5 working days — bearing in mind that stock held in a British warehouse is itself treated as an importation.
The deemed-supplier collection rules imposed on marketplaces: for goods imported in parcels with a value not exceeding £135, the marketplace (Amazon, eBay, etc.) is generally deemed the supplier and charges the British VAT itself.
The filing of British VAT returns on HMRC's schedule, alongside your EU returns — a second compliance rhythm to keep without interruption.
The UK is too important a market for most e-commerce merchants to ignore, but its compliance cannot be improvised. It is a complete regulatory file, parallel to your EU setup, that is best entrusted to a partner who masters both sides of the Channel.
The EU-base advantageWhen is a fiscal representative mandatory?
Some member states require a company not established on their territory to appoint a fiscal representative — a local entity jointly liable for your VAT obligations. This adds cost and complexity, and it is a major point of friction for structures based outside the EU (Dubai, Hong Kong, etc.).
A Bulgarian company (DPK/EDPK, or EOOD), however, is by definition established within the single market. Inside the EU, it is most often exempt from the fiscal-representation obligation, which appreciably reduces the cost of a multi-country rollout compared with a non-European holding.
This is one of the decisive arguments for the choice of Bulgaria to form your company when you sell across several markets. The full comparison: Bulgaria vs Estonia vs Dubai vs France.
For a 100% remote formation, with no capital deposit or prior bank account, the DPK/EDPK is often the simplest choice; the EOOD (or the OOD with several shareholders) remains the classic form, with a capital deposit through a Bulgarian bank — see EOOD, OOD or DPK.
Starting from an EU base such as Bulgaria wins on two fronts — direct access to the OSS for sales flows, and frequent exemption from a fiscal representative for local registrations.
How much does multi-country VAT cost?
The cost of a multi-country VAT setup breaks down between one-off registration fees and the recurring filing of returns:
| Item | Indicative amount |
|---|---|
| EU VAT registration (per country) | from €125 excl. VAT (one-off) |
| OSS / IOSS registration | from €250 excl. VAT (one-off) |
| Bookkeeping & periodic returns | from €179 excl. VAT/month |
| VAT GB & GB EORI (United Kingdom) | quoted case by case |
The real hidden cost is not the registration fee: it is the risk of missing an obligation and exposing yourself to reassessments, penalties and seller-account suspensions. Centralising the management with a single provider is often worth far more than saving a few dozen euros per country.
How does Fenchell manage all of this?
This whole architecture rests on one foundation: your company. Once your Bulgarian EOOD is formed with the Eurotrade pack (from €890 excl. VAT, EIK + VAT + help assembling your bank accounts, which you open yourself, + support) — a 100% remote process whose EOOD formation steps we detail — Fenchell becomes your single point of contact for the entire VAT setup.
The firm, physically present in Plovdiv since 2018 and with nearly 1,000 companies formed (Ekomi rating 4.8/5), centralises everything thanks to its team and its network of dedicated partners — partner accounting firm, lawyers, marketplace-account managers — that is, 10 to 20 people mobilised depending on the complexity of your file:
Your VAT numbers in each FBA country of storage — Germany, Poland, the Czech Republic, France, Italy, Spain — obtained and kept up to date.
Your OSS / IOSS registration for distance sales, declared through the Bulgarian one-stop shop.
Your VAT GB and GB EORI numbers for the post-Brexit British market, handled in parallel with your EU setup.
The regular filing of all your periodic returns, EU and UK alike, with no break in schedule.
This genuine presence also constitutes your economic substance — the condition for a setup that is defensible before tax authorities and banks alike. Instead of juggling a different provider per country, you keep a single point of contact who knows your file from end to end.
Obtaining the registration is only one line of the equation — the one any generic incorporation produces, wherever it is done. The Eurotrade pack is not a registration with options bolted on: it is an integrated, inseparable system.
1 — A file designed for remote management
The file contains more than 20 bilingual documents in Bulgarian/English — more than 30 for multi-shareholder companies — all designed by Fenchell's legal team specifically for remote management, drawing on years of experience and thousands of real client cases:
- the articles of association;
- the 8 notarised powers of attorney;
- the stamped registration certificate with its sworn translation;
- the FID (personal tax number);
- the QES key (qualified electronic signature) and many others.
2 — An operability infrastructure built in from the outset
Operability is not bolted on afterwards: it is built in from the outset, within the file itself:
- bookkeeping and VAT compliance managed locally;
- a dedicated web interface to read live, from any device, your SMS (OTP / 2FA codes from banks and platforms) received on your active Bulgarian mobile line;
- office and registered address in Plovdiv with mail collection and scanning;
- registration of the point of contact (POC, AML/MAMLA compliance);
- help assembling bank and fintech account-opening files, remotely — the client remains the applicant and the holder;
- optional dedicated static IP.
It is this integrated infrastructure that creates the genuine economic substance — the kind that makes your multi-country VAT truly workable and your setup defensible, rather than an empty shell. Everything is gathered in the Eurotrade pack.
Roll out your multi-country VAT without errors
Fenchell manages your entire multi-country VAT compliance from Plovdiv, under a single point of contact. It all starts with your Bulgarian company with the Eurotrade pack, from €890 excl. VAT.
FAQ
Why is the OSS one-stop shop not enough if I store via FBA?
Is the United Kingdom covered by the European OSS?
What is a fiscal representative and when is it mandatory?
How much does a VAT registration in an additional country cost?
Does Fenchell manage all my multi-country returns?
General information current as of 8 June 2026, not constituting personalised tax, legal or accounting advice. Rates, deadlines, thresholds and amounts are indicative and vary according to your situation and the countries concerned. Fenchell Capital OOD — Bulgarian firm based in Plovdiv (EIK 207945095).