The Amazon VAT threshold UK sellers get wrong before Pan-EU FBA

Ask ten UK sellers what the Amazon VAT threshold is and most will say £90,000. Ask them what happens to that threshold the day Amazon moves their stock into a German fulfilment centre under Pan-EU FBA and the answers get vaguer. That gap is where the surprise VAT bills live. There are two threshold figures a UK seller reads about when planning European expansion, and the uncomfortable part is that once inventory is sitting inside the EU, neither of them is the test that decides whether you must register.

This post sets out what each figure actually covers, using the wording from HMRC, GOV.UK, the European Commission and Amazon’s own Pan-European FBA page, so the question you take to your accountant is a precise one. It is not tax advice. It is the reference you should have in front of you before you enable storage in a second country.

The UK VAT threshold is a turnover test, and only for UK-based businesses

Start with the number everyone knows. The UK VAT registration threshold rose from £85,000 to £90,000 on 1 April 2024, and the deregistration threshold rose from £83,000 to £88,000 at the same time, per GOV.UK’s policy paper on the change. The test is your total taxable turnover over the last 12 months, measured on a rolling basis, not by tax year. GOV.UK’s Register for VAT guidance adds two details sellers skip. You must register within 30 days of the end of the month in which you went over, and you must also register if you realise your turnover will pass £90,000 in the next 30 days alone, which is exactly what a strong Q4 can do to a business that was comfortably under the line in September.

The part that matters for this discussion is who the threshold applies to. The same GOV.UK page states that a business based outside the UK that supplies any goods or services to the UK must register regardless of taxable turnover. There is no £90,000 allowance for an overseas seller. A German company holding stock in a UK fulfilment centre registers from the first sale. Keep that principle in mind, because the EU applies the same logic to you the moment your goods cross the other way.

One reason the £90,000 figure gets misquoted is that older material still carries the previous number. Amazon’s own VAT Knowledge Centre page for UK sellers still describes the UK domestic threshold as £85,000, checked on 16/09/2026. If you are working from a saved guide, a supplier’s onboarding deck or a marketplace help page, verify the figure against GOV.UK before you build a forecast on it.

The €10,000 EU threshold does not apply to a UK seller at all

The second figure is the one that causes real damage, because it is quoted constantly and almost always without its conditions. Under the EU’s One Stop Shop rules, an annual €10,000 threshold lets a supplier keep applying its home country’s VAT rules to cross-border B2C sales, with VAT only becoming due in the customer’s country once the threshold is passed. From 1 July 2021 that threshold was extended from digital services to intra-Community distance sales of goods. Sellers read this as “I can sell up to €10,000 across the EU before I have to think about foreign VAT”. That reading is wrong for a business established in the UK.

The European Commission’s One Stop Shop portal sets out the conditions in section 9. The threshold is available only where the supplier is established, or in the absence of an establishment has its permanent address or usually resides, in only one Member State. It covers goods whose dispatch started in that same Member State. And the €10,000 limit is measured across the current and the preceding calendar year, as a single EU-wide total, not a fresh €10,000 per country. A UK limited company with no EU establishment fails the first condition before the arithmetic even starts. It has no €10,000 allowance. The Commission’s Register to OSS page confirms that a taxable person not established in the EU can still use the Union scheme to declare intra-Community distance sales, but using the scheme to report VAT is a different thing from having a threshold below which no VAT is due.

For a seller who is established in one EU country and does qualify, note the trap in the other direction. The Commission states that a supplier who opts out of the threshold and applies the destination country’s rules is bound by that decision for two calendar years. Thresholds in EU VAT are not a dial you turn each quarter.

Under Pan-EU FBA there is no Amazon VAT threshold, only the local rules

Now put stock into the programme. Amazon’s Pan-European FBA page for UK sellers currently lists France, Germany, Italy, Spain and Poland as storage countries, asks you to enable storage in at least two of them, and carries this footnote against that instruction: by storing goods in countries other than your home store, you will have additional VAT reporting requirements. The same page says you can start with just two VAT numbers, which is true, and which is also the sentence that lulls people. Two VAT numbers is where you start. Amazon then stores inventory in whichever of the enabled countries it chooses, and each new storage country is a new registration question.

What decides that question is not a turnover figure. HMRC’s own place of supply manual, VATPOSG2400, puts it in one sentence: “Liability to register (and any consequent requirement to appoint a local tax representative) is governed by the rules as they are applied in the Member State concerned.” HMRC goes further and instructs its own staff not to give an opinion on whether a UK business needs to register abroad, directing the enquiry to the tax authority of the Member State in question. If HMRC will not guess, you should not either. Amazon’s VAT Knowledge Centre page spells out the practical consequence for the main storage countries: you need to register for VAT in Germany if you store goods in Germany, and Italy and Spain are described the same way. Storage is the trigger. It is the mirror image of the GOV.UK rule for overseas sellers holding stock in the UK. The existing VendLab Amazon VAT and tax guide covers the registration mechanics and reporting cycles country by country, so this post will not repeat them.

The programme is also getting wider, which means more storage countries to plan for. Amazon’s page states that from 3 September 2026 all Pan-EU FBA products, new and existing, must have an active Netherlands offer to enrol and to keep receiving Pan-EU benefits, and that from 26 February 2027 all Pan-EU FBA products must also have an active offer in Belgium at enrolment. Whether an active offer in a marketplace leads to stock being stored in that country is a question for Amazon and your accountant, but it is a question to ask before the date, not after a local tax office writes to you. VendLab’s Pan-European FBA guide walks through the programme’s structure if you are weighing it against European Fulfilment Network shipping from the UK.

The check to run before you enable a second storage country

Take the table above into a meeting with a VAT specialist and ask three things. Which of the storage countries Amazon may place my stock in do I hold a VAT number for today? For each country I do not, what is the lead time to register and what does a fiscal representative cost if one is required? And what happens to my UK position if a peak season pushes me past £90,000 in a single 30-day window? The answers turn Pan-EU FBA from a gamble into a costed decision, and Amazon’s headline claim of up to 53% savings in fulfilment fees against European Fulfilment Network rates only means something once the registration and filing costs sit on the same page.

The sellers who get caught usually knew a threshold figure, assumed it protected them, and found out that the figure belonged to a different business in a different country. If you want a second pair of eyes on your expansion plan before you switch storage on, VendLab’s Amazon consulting services start with exactly this kind of pre-flight check. Sources checked on 16/09/2026: GOV.UK (VAT threshold policy paper and Register for VAT), HMRC manual VATPOSG2400, the European Commission One Stop Shop portal, and Amazon’s Pan-European FBA and VAT Knowledge Centre pages for UK sellers.