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Consignment Stock

The European Council conclusions and discussions with the Member States and other stakeholders on the VAT Action Plan has shown a need to introduce certain short-term improvements to the current VAT system ("quick fixes"). Those four quick fixes are proposed this year together with the legal cornerstones of the definitive VAT system.

A proposal in 2018 will further provide detailed technical provisions for the actual implementation of the first step of the definitive VAT system.

The October 2017 definitive VAT system package consists, among others, in the simplification and harmonization of rules regarding call-off stock arrangements.

Call-off stock refers to the situation where a supplier moves stock to a Member State where he is not established, in order to sell it at a later stage to an already known buyer.

Currently this gives rise to different complex treatment:

1.    A deemed intra-Community supply made by the transferor.

2.    A deemed intra-Community acquisition in the Member State of arrival of the goods made by the transferor who has to register there.

In the case of “call-off stock” the Spanish VAT regulations had opted for the first system that generates many administrative difficulties for the parties involved.

In the case of “consignment stock” there are also difficulties to overcome.


The consignment stock applies in case of goods delivered to storage facilities operated directly by the supplier or in his name, rather than the customer. The stocks of goods are dispatched by an EU supplier to the Spanish facilities with potential destination to more than one customer. In this case, the second option will apply.