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FLEX. Logistics
We provide logistics services to online retailers in Europe: Amazon FBA prep, processing FBA removal orders, forwarding to Fulfillment Centers - both FBA and Vendor shipments.
The EU Parliament is actively reconsidering the optional VAT reverse charge mechanism — whose current authorisation expires at the end of 2026 — amid concerns about VAT fraud and the argument that advancing digital reporting under ViDA makes the mechanism less necessary. For cross-border B2B e-commerce sellers operating between EU member states, particularly those using 3PL infrastructure in Germany, France and Poland, this is a compliance planning event that has received almost no attention in Amazon-seller-focused content. The reverse charge mechanism is the mechanism that allows B2B sellers to issue invoices without charging VAT — shifting the VAT accounting obligation to the buyer. If its authorisation expires without renewal, modified, or replaced, sellers who have been relying on it for cross-border B2B transactions will face a changed VAT charging obligation on their EU B2B sales. This article explains what the reverse charge mechanism currently allows, what the Parliament's reconsideration means for the three most likely outcomes, and the concrete compliance steps sellers should take before the end of 2026 authorisation date.
What the EU VAT Reverse Charge Mechanism Currently Allows — and Who Uses It
The reverse charge mechanism in EU VAT law allows a VAT-registered supplier to issue a B2B invoice without charging VAT, provided both the supplier and the buyer are VAT-registered in EU member states. Instead of the supplier collecting VAT and remitting it to the tax authority, the buyer self-accounts for the VAT — declaring it as both output tax (as if they had charged it) and input tax (as the recipient of the supply) in their own VAT return. The net VAT effect for a fully taxable buyer is zero — they owe the output VAT but reclaim the input VAT simultaneously. The mechanism eliminates the cash flow burden on the buyer (who does not need to pay VAT upfront and wait for the input reclaim) and reduces the administrative load on the supplier (who does not need to collect and remit VAT in the buyer's country).
For e-commerce sellers and their 3PL partners, the reverse charge applies in two common scenarios: cross-border B2B goods sales within the EU (a German seller supplying goods to a French business buyer — the French buyer accounts for French VAT under reverse charge rather than the German seller registering in France to charge French VAT), and B2B services supplied cross-border within the EU (a Polish 3PL invoicing a UK-registered business for warehousing services — the UK business accounts for the VAT under the general B2B service place-of-supply rule, reverse charge applies). The mechanism is fundamental to how cross-border B2B supply chains in the EU avoid requiring suppliers to VAT-register in every country where they have business customers.
The optional domestic reverse charge — which allows member states to apply reverse charge to certain domestic B2B transactions as a VAT fraud prevention measure — is the specific mechanism under reconsideration. This is distinct from the mandatory cross-border reverse charge on intra-EU B2B transactions, which is a permanent feature of EU VAT law and is not affected by the current Parliament discussion. The distinction matters significantly for sellers: the cross-border B2B reverse charge that most e-commerce sellers rely on for their intra-EU B2B sales is not at risk. The domestic reverse charge that some member states use for specific sectors is what is being reviewed. EU customs clearance and cross-border VAT compliance at FLEX. tracks VAT mechanism changes across Germany, France and Poland and advises on seller implications.
What the EU Parliament's Reconsideration Actually Covers
The EU Parliament's reconsideration focuses on the optional domestic reverse charge mechanism — specifically the Article 199a and 199b derogations that allow member states to apply domestic reverse charge to specific high-fraud-risk sectors and transactions. These derogations expire at end of 2026 and require renewal by unanimous Council agreement. The Parliament's concern: as ViDA's digital reporting infrastructure matures, the argument for domestic reverse charge as a VAT fraud prevention tool weakens — because real-time digital reporting provides tax authorities with the transaction-level visibility that domestic reverse charge was designed to provide by other means.
The three plausible outcomes of the Parliament's reconsideration:
Outcome 1 — Full renewal: The Council agrees unanimously to renew the domestic reverse charge derogations for a further period, maintaining the current mechanism in all member states that use it. This is the most politically likely outcome in the short term — member states that use domestic reverse charge (notably Germany, which applies it to certain construction, mobile phone, and electronic goods transactions) will resist non-renewal. Seller impact: no change. Probability: high for a 2-to-3-year renewal; moderate for a long-term renewal.
Outcome 2 — Partial renewal with conditions: The Council renews with modifications — tightening the conditions for domestic reverse charge use, reducing the sectors covered, or linking renewal to ViDA implementation progress. Specific sectors currently using domestic reverse charge in Germany (mobile phones and other electronic devices above EUR 5,000 per transaction; construction services; wholesale delivery of gas and electricity) might be removed from the domestic reverse charge scope. Seller impact: sellers making B2B sales in affected categories to German buyers would need to charge German VAT rather than applying domestic reverse charge, requiring German VAT registration if not already registered. Probability: moderate.
Outcome 3 — Non-renewal: The Council fails to reach unanimous agreement and the domestic reverse charge derogations expire at end of 2026. Every transaction category currently covered by domestic reverse charge in each member state reverts to standard VAT charging — the supplier charges VAT, the buyer reclaims it. For sellers making high-value B2B sales in affected categories (electronic goods, construction services, etc.), this means VAT registration in the buyer's country becomes necessary to charge VAT correctly. Probability: low for immediate non-renewal but increasing if ViDA implementation accelerates and the fraud-prevention justification weakens. Pre-Amazon storage in Europe at FLEX. operates across Germany, Poland and France — all three countries where domestic reverse charge applies in specific sectors.
Which Amazon Sellers and B2B E-Commerce Businesses Are Actually at Risk
The critical distinction — which most existing content on this topic conflates — is between the domestic reverse charge and the cross-border reverse charge. For most Amazon FBA sellers making B2C sales and for sellers making cross-border B2B sales to buyers in other EU countries, the mechanism under reconsideration does not apply. The cross-border intra-EU reverse charge is mandatory EU VAT law and is not affected by the domestic derogation review.
Sellers who face genuine exposure from the domestic reverse charge reconsideration:
Sellers making domestic B2B sales in Germany above EUR 5,000 per transaction in electronic goods. If you sell consumer electronics, mobile phones, tablets, or similar goods to German business buyers in transactions above EUR 5,000, the German domestic reverse charge currently applies — you issue a net invoice and the German buyer accounts for German VAT. If this derogation is not renewed, you would need to charge 19% German VAT on these transactions, requiring a German VAT registration to collect and remit it. This primarily affects wholesale and B2B marketplace sellers, not retail FBA sellers whose primary channel is Amazon B2C.
Sellers providing construction services in Germany or France. The construction sector domestic reverse charge in Germany and France covers labour and materials supplied in construction projects above certain thresholds. B2B e-commerce sellers are unlikely to be affected by this category.
Cross-border sellers whose buyers incorrectly rely on domestic reverse charge for intra-EU transactions. The most common practical compliance error related to reverse charge: a seller applies domestic reverse charge to a cross-border sale where the buyer is in another EU country, rather than applying the mandatory intra-EU cross-border reverse charge. These are different mechanisms and the invoicing treatment must reflect which applies. If a seller's invoicing system conflates the two, the domestic reverse charge reconsideration creates an audit risk even for sellers not directly in scope. Amazon FBA prep services in Europe at FLEX. operates with separate VAT registrations in Germany, Poland and France, applying the correct reverse charge treatment per transaction type and jurisdiction.
How the Cross-Border Reverse Charge — Which Is Not Affected — Works in Practice
Because confusion between domestic and cross-border reverse charge is the most common compliance error in this area, it is worth explaining precisely how the cross-border mechanism works for e-commerce sellers — and confirming that it is not the mechanism under Parliamentary reconsideration.
When a German-registered seller sells goods to a French-registered business buyer and the goods are transported from Germany to France, the transaction is an intra-community supply (innergemeinschaftliche Lieferung). The German seller issues an invoice without German VAT — the invoice must show the buyer's French VAT number and the notation 'VAT: reverse charge — intra-community supply, Art. 138 EU VAT Directive'. The French buyer accounts for French VAT on the acquisition in their French VAT return as both output and input tax. The German seller has no French VAT registration obligation for this transaction.
This mechanism is a mandatory feature of the EU VAT Directive — it is not an optional derogation that requires renewal. Its continued operation is not subject to the current Parliamentary review. Sellers who make cross-border B2B sales within the EU — including 3PL-to-business-client invoicing across borders, cross-border wholesale supply, and intra-company stock transfers between group entities in different EU countries — can plan on this mechanism continuing regardless of what happens to the domestic reverse charge derogation review. The only caveat: the buyer's VAT number must be verified via the EU VIES system before applying the zero-VAT reverse charge invoice — if the buyer's VAT number is invalid, the seller owes the VAT. B2C and B2B fulfillment in Europe at FLEX. issues invoices under the correct reverse charge treatment for cross-border B2B transactions, with VIES verification of client VAT numbers as part of the standard invoicing workflow.
What the 3PL's VAT Registration Position Means for Your Compliance
For e-commerce sellers using a 3PL across multiple EU countries, the 3PL's VAT registration position in each operating country directly affects the seller's VAT compliance. Three scenarios where the 3PL's VAT position creates seller-side implications:
3PL invoicing for services in countries where it is not VAT-registered. A 3PL that provides warehousing and fulfilment services in Germany but is not German-VAT-registered cannot issue a German-VAT-compliant invoice — it cannot charge 19% German VAT or apply the reverse charge correctly for cross-border B2B clients. For sellers who need to reclaim German input VAT on logistics costs, the 3PL must be German-VAT-registered. A 3PL operating in Germany without German VAT registration is a compliance red flag that creates input VAT reclaim problems for its clients.
3PL acting as importer of record without the correct VAT registration for import duty reclaim. When a 3PL acts as importer of record for an inbound container — accepting customs liability and paying import VAT at Hamburg on behalf of the seller — the import VAT certificate is issued in the 3PL's name. If the seller wants to reclaim the import VAT through their own German VAT return, the import VAT certificate must identify the seller as the importer, not the 3PL. Clarifying the importer of record structure — who is named on the customs declaration, and therefore who can reclaim the import VAT — is an important step before the first inbound shipment, not after the first customs invoice arrives.
3PL issuing domestic reverse charge invoices in categories currently covered by the derogation. For high-value B2B transactions in covered categories (electronic goods above EUR 5,000 in Germany), a 3PL that correctly applies domestic reverse charge must be German-VAT-registered and must issue the invoice with the correct domestic reverse charge notation. If the domestic reverse charge derogation is modified or not renewed, the 3PL must update its invoicing system to charge VAT on these transactions — and must be registered to collect and remit it. EU customs clearance and VAT compliance at FLEX. operates with VAT registrations in Germany, Poland and France, with invoicing systems that apply the correct VAT treatment — domestic reverse charge, cross-border reverse charge, or standard rated — per transaction type and jurisdiction.
Compliance Checklist: What to Do Before End of 2026
1. Identify whether your B2B sales fall within domestic reverse charge categories in your operating countries. In Germany: electronic goods and mobile phones above EUR 5,000 per transaction, certain construction services, wholesale gas and electricity delivery. In France: construction services, certain carbon trading transactions. In Poland: certain electronic goods and construction services. If your B2B sales include any of these categories in these countries, you are in scope for the domestic reverse charge reconsideration — flag this for your VAT advisor review before Q4 2026.
2. Verify that your invoicing system distinguishes correctly between domestic reverse charge and cross-border reverse charge. These are different mechanisms with different invoice notations, different buyer requirements, and different VAT reporting treatments. An invoicing system that applies a generic 'reverse charge' label without specifying which mechanism applies is creating documentation that will not withstand a VAT audit. Correct notation for cross-border: 'VAT: reverse charge — intra-community supply, Art. 138 EU VAT Directive'. Correct notation for domestic (Germany): 'Steuerschuldnerschaft des Leistungsempfängers gemäß §13b UStG'.
3. Verify your buyers' VAT numbers via EU VIES before issuing zero-VAT reverse charge invoices. VIES verification is a legal requirement for applying the zero-VAT cross-border reverse charge — an invalid buyer VAT number means the supplier owes the VAT. Run VIES checks at least quarterly for all active B2B clients, and at the time of issuing each invoice for new clients.
4. Confirm your 3PL's VAT registration in each country where you hold inventory. Ask specifically: are you VAT-registered in Germany, France and Poland? Can you provide your VAT registration number for each country? Are your invoices issued with the correct VAT treatment for cross-border B2B clients? A 3PL that cannot answer these questions clearly is a compliance risk for your input VAT reclaim and your reverse charge documentation.
5. Monitor the EU Parliament and Council position on domestic reverse charge renewal through Q3 2026. The legislative process will become clearer as the end-of-2026 authorisation deadline approaches. Your VAT advisor should be tracking this and providing a position update by September 2026 at the latest — giving you Q4 2026 to make any necessary invoicing or registration adjustments before the year-end expiry. Pre-Amazon storage in Europe at FLEX. provides unified VAT-compliant invoicing across Germany, Poland and France for sellers managing multi-country EU operations.
Domestic Reverse Charge Review Requires Early VAT Checks
The EU Parliament's reconsideration of the domestic reverse charge mechanism is a regulatory pipeline event that affects a specific and identifiable subset of cross-border B2B e-commerce sellers — primarily those making high-value B2B sales in electronic goods or construction-related categories in Germany, France, or Poland. For the majority of Amazon FBA sellers whose primary channel is B2C, and for sellers making standard cross-border B2B intra-EU sales, the mechanism under review does not apply and the cross-border reverse charge that governs their transactions is not at risk. The compliance action for all sellers regardless of whether they are directly in scope: verify that your invoicing system applies the correct reverse charge mechanism and notation, verify your buyers' VAT numbers via VIES, confirm your 3PL's VAT registration in each operating country, and engage your VAT advisor on the domestic reverse charge review timeline before Q4 2026. The sellers who discover they are in scope for the domestic reverse charge reconsideration in November 2026 will have insufficient time to make the necessary registration and system changes before year-end. The sellers who review their position now have nine months to prepare.
Located in Central Europe, FLEX. Logistics provides pre-Amazon storage, FBA prep and B2C fulfillment across Germany, Poland and France — with VAT registrations in all three countries, correct reverse charge treatment per transaction type, and unified invoicing that supports multi-country VAT compliance for cross-border e-commerce sellers.
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