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What to keep in mind when storing goods in other EU countries

Storing goods in warehouses located closer to the client gives an advantage to companies trading in goods by facilitating cooperation and ensuring a smoother flow of goods.

In light of this year's amendments to the Estonian Value-Added Tax Act, regarding the addition of the term call-off stock to Estonian VAT treatment, we feel it is necessary to give a brief overview of different storing types, which are relevant in terms of VAT calculation and liability to pay VAT. Two categories of warehouses are usually identified with regard to the movement of goods within the EU: consignment warehouses and warehouses for building call-off stock.

When determining the warehouse category, consideration is given to who will have possession of the goods stored in the warehouse and who will have direct control of the stock until the goods are delivered to the consumer.

A consignment warehouse or commission warehouse is used by sellers to store goods which they own and have control over and which they will subsequently deliver to consumers. As a rule, goods are delivered to consumers in own name and at own cost and there are no predetermined consumers when the goods first arrive at the warehouse. In terms of taxes, the seller is liable to VAT in the country where the warehouse is located.

Sending goods to a call-off stock warehouse is, in essence, the dispatch of goods to predetermined clients who take control over the said goods while the seller maintains possession of the goods – possession is transferred to clients only when they decide to take the goods into use from the warehouse (even if for resale). When the conditions provided for in the Act are met, the dispatch of goods to a call-off stock warehouse located in another Member State will not make the seller liable to VAT in that state. For more information please visit

Feel free to contact Leinonen's Tax Team if you have additional questions.

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Jelena Dudko

Tax Advisor

+372 6117 700

Email: jelena.dudko(at)

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