Why Amazon FBA creates a VAT obligation in France
The Fulfillment by Amazon (FBA) programme allows sellers worldwide to store their goods in Amazon warehouses so that Amazon manages the logistics. When these warehouses are located in France, this creates a specific tax situation: the seller has stock on French territory.
Under French tax law, holding goods in France is treated as carrying out taxable transactions on the territory. Article 256 of the French General Tax Code (CGI) provides that a supply of goods is taxable in France when the goods are located in France at the time of transfer of ownership. As a result:
- Sending stock from abroad to an Amazon France warehouse constitutes an import or intra-community acquisition subject to VAT.
- Each sale dispatched from the French warehouse is a supply of goods subject to French VAT.
- Stock transfers between Amazon warehouses (from an EU country to France, or from France to another EU country) constitute intra-community movements that must be declared.
Concrete case
A Korean seller sends 500 units of their product to Amazon's CDG7 warehouse (Paris). As soon as the stock arrives in France, they become liable for French VAT on all transactions related to that stock. They must be registered for French VAT and, as a non-EU seller, have an accredited tax representative.
OSS, IOSS or accredited tax representative: which to choose?
The July 2021 e-commerce VAT reform introduced the OSS (One-Stop Shop) and IOSS (Import One-Stop Shop). It is important to understand what these schemes cover — and what they do not.
- OSS (Union Scheme): allows VAT on B2C distance sales to EU consumers to be declared in a single member state. It covers sales only — not stock operations, not intra-community acquisitions. It is only accessible to EU-established businesses.
- IOSS: covers B2C sales of imported goods valued below €150. It is accessible to non-EU sellers through an accredited tax intermediary. It does not cover FBA sales from stock already in France.
- Accredited tax representative: mandatory for non-EU sellers as soon as they have stock in France. They manage French VAT returns, stock movements, and transactions not covered by OSS or IOSS.
Rule to remember
For a non-EU Amazon FBA seller with stock in France: OSS + IOSS can complement but do not replace the accredited tax representative. All three can coexist to cover different types of transactions.
How to achieve compliance: the concrete steps
If you are a non-EU Amazon FBA seller using warehouses in France, here is the procedure to follow to be compliant:
- Step 1 — Identify your active warehouses in France: check in Amazon Seller Central which warehouses your stock is currently stored in. Warehouse codes starting with "CDG" or located in France are indicators.
- Step 2 — Appoint a DGFiP-accredited tax representative: sign a mandate with a firm specialising in e-commerce. Our list of accredited representatives includes firms experienced in Amazon FBA flows.
- Step 3 — French VAT registration: your representative submits the file to the SIEE (Foreign Companies Tax Office). Timeline: 4 to 8 weeks.
- Step 4 — Retrieve Amazon VAT reports: download the transaction, inventory, and transfer reports from Seller Central. Send them monthly to your representative for the CA3 returns.
- Step 5 — Regularise past periods: if stock has been in France for some time without returns being filed, a voluntary regularisation is strongly recommended.
Concrete example
A US company has been selling electronic accessories on Amazon.fr for 18 months via FBA. It has never been registered for French VAT. The regularisation covers 18 months of undeclared VAT on sales made from French stock, plus 10% late payment penalties. Its accredited tax representative prepares the voluntary regularisation file to limit penalties.
Risks of VAT non-compliance for Amazon FBA
Amazon has been placing increasing pressure on its sellers since 2026 to be VAT-compliant. The risks of non-compliance are multiple:
- Amazon account suspension: Amazon can suspend accounts of non-compliant sellers following requests from tax authorities or during random checks.
- DGFiP tax reassessment: the French authorities can carry out a reassessment covering the last 3 years of undeclared activity, with penalties of 10% to 40% of amounts owed.
- Import blockage: French customs may refuse entry of goods if the company is not properly registered for VAT.
- Administrative fines: the absence of an accredited tax representative can result in specific administrative fines.
Urgency of compliance
If you have Amazon stock in France without VAT registration or an accredited tax representative, every additional week worsens the potential reassessment. Voluntary regularisation, even late, is always preferable to an imposed tax audit.
Find an accredited tax representative specialising in Amazon sellers and e-commerce flows by consulting our list of DGFiP-accredited tax representatives. Several firms there are well versed in FBA and Seller Central issues.
Frequently asked questions
Yes, as soon as Amazon stores their goods in a logistics warehouse located in France (Amazon FR distribution centre), the non-EU seller has stock on French territory. This constitutes a taxable transaction on French soil and triggers the accredited VAT tax representative obligation, regardless of sales volume.
Partially. Amazon collects and remits VAT for transactions made via its marketplace platform under the "deemed supplier" rules (since July 2021). But this does not exempt the seller from registering for French VAT, filing returns, and — for non-EU sellers — having an accredited tax representative for stock-related transactions.
Amazon's Pan-European FBA programme distributes the seller's stock across multiple European warehouses according to demand. If stock is placed in France, the French VAT obligation applies. This programme can therefore create VAT obligations in several EU countries simultaneously. OSS can cover B2C sales, but local registration remains necessary for stock flows.
No. OSS only covers B2C distance sales to EU consumers. It does not cover stock operations in France (warehouse intake, inter-warehouse Amazon transfers). These transactions require a separate French VAT registration, and for non-EU sellers, an accredited tax representative.
Amazon makes several VAT reports available in Seller Central: the transactions report, the inventory report by warehouse, and the inter-warehouse transfer report. These documents are essential for your tax representative to prepare your French VAT returns accurately. Verify that your tax representative is familiar with the Amazon Seller Central interface.