Frequently asked questions

What is commingling?

Commingling transactions are inventory swaps between two FBA (Fulfilment by Amazon) sellers, or between an FBA seller and Amazon Retail within the commingling programme. Items in your inventory that are identified using manufacturer barcodes are commingled with items of the exact same products from other sellers who also use manufacturer barcodes for those items.

The commingling swaps can occur either locally in one country (domestic commingling) or cross-border* in the EU6 and UK (cross-border commingling).

* Additional seller eligibility requirements apply.

How does Amazon track my commingled inventory?

Even though your inventory does not have additional labels, Amazon will assign a virtual trackable label to your units once they have been received. Virtual trackable labels allow Amazon to keep a track of your inventory at all the times.

What are the prerequisites for domestic and cross-border commingling?

Your eligible products with Manufacturer barcode can be commingled domestically if valid VAT (Value added tax) numbers are provided in the respective countries where inventory is stored.

To participate in cross-border commingling, your ASINs must be enrolled in the FBA Pan-EU program and you have provided valid VAT numbers to Amazon in at least two out of the 7 countries (UK, Germany, Spain, Italy, France, Poland, Czech Republish). Commingling may only occur for the countries for which you provide a valid VAT number.

What is VAT and am I obliged to register for VAT in a country?

VAT, in the European Union and the UK, is a consumption tax assessed on the value added to goods and services. It applies to goods and services that are bought and sold for use or consumption in the European Union and the UK. For more information, please refer to this page and consult your tax advisor.

Is commingling subject to VAT and if so, why?

Yes. Commingling is a swap of products between two sellers and qualifies as a supply of goods for VAT purposes in the countries involved in the swap (two countries for cross-border, one country for domestic).

What is the role of Amazon?

By participating in the FBA commingling programme, you allow Amazon to commingle your exact same products with other sellers. Amazon decides when commingling will take place and executes the required swaps.

From a legal point of view, Amazon is not taking any legal title or ownership of products of either seller at any time in the process.

How will the commingled transactions be invoiced for VAT?

When a product is commingled, Amazon will issue two (additional) invoices to record the inventory swap:

• Self-bill invoice for the disposal of your product, including the taxable base and the VAT payable amount.
• Invoice for the acquisition of other seller’s same product, including the taxable base and the VAT receivable* amount.

These additional invoices will be generated on a monthly basis showing aggregated commingled transactions per country.

* Input VAT is the VAT mentioned on your incoming invoices from Amazon. Usually, input VAT is deductible but we advise you to contact your tax advisor in case of questions to obtain confirmation.

How is VAT being calculated on my inventory items in case of commingling?

Your offer price of the listing in the marketplace of disposal will be taken into account to calculate the taxable base (the amount on which the VAT amount will be calculated). The resultant taxable base will be used to compute the corresponding VAT amount for the acquisition of the other sellers’ exact same product.

In case you are a VCS-seller, Amazon will take the PTC that you have assigned to your offer and use the corresponding VAT rate. If you have not activated VCS, Amazon will assign the PTC and corresponding VAT rate.

In case of the acquisition of the product from another FBA seller/Amazon Retail, Amazon will always use the PTC assigned by Amazon.

We therefore advise you to review the calculations made and if you do not agree with the calculations, contact Seller Support.

Although my products are not zero-rated, there is no VAT mentioned on the invoice?

In principle, sellers should charge VAT due on the supply of goods and should pay this VAT towards the tax authorities. In certain countries (Czech Republic, France, Italy, Poland, Spain) and certain cases (depending on establishment/registration in the respective country), a local reverse charge mechanism applies. This means that the VAT due is not charged on the invoice by the supplier but is accounted for by the customer. The customer then needs to report the VAT due in his VAT return but can deduct this VAT amount in the same VAT return (generally no cash-flow impact).

In case of commingling, a local reverse charge mechanism may apply:

• For the disposal of the product: you only need to report the taxable base in your VAT return. Amazon will account for the VAT due in its own VAT return.
• For the acquisition of the other seller’s exact same product: you will need to report the taxable base and the corresponding VAT due and VAT deductible amount in your VAT return. Consult your tax advisor for the correct reporting requirements.

Which VAT numbers do I need for participating in the commingling programme?

In principle, you always require a VAT registration in the country where you hold inventory.

Commingling transactions may only take place in case you have a valid VAT number in the country/countries where both fulfilment centres are located. Our system is set up to verify if the VAT numbers provided through Seller Central are valid and will only proceed in case a valid VAT number in both countries is provided.

Where can I add my VAT numbers in Seller Central?

Visit the VAT/GST registration numbers page, and enter your available VAT numbers by country.

How do I report these transactions in my VAT return?

When preparing your VAT reporting, these commingled transactions should be treated the same as any of your other local sale (Commingling_SELL) and purchase (Commingling_BUY) transactions. These commingling transactions will be reported in your Amazon VAT Transactions Report.

The fields Total activity value amount excluding VAT and the VAT amount for both Commingling_Sell and Commingling_Buy transactions are shown as a positive value in your AVTR. Therefore, make sure that you correctly calculate your final VAT position.

For more information, go to this page.

What is a self-bill?

By default, the supplier is required to issue a VAT compliant invoice to its customer. Parties can agree to self-bill which means that the customer prepares the supplier’s invoice in the name and on behalf of the supplier. The self-billing process lowers the administrative burden for the sellers.

For commingling transactions, Amazon will issue a self-bill invoice for all the disposals of products to another participating FBA seller (or Amazon Retail), per country on a monthly basis. Self-billing is in accordance with the Amazon Services Europe Business Solutions Agreement. The self-bill invoice at a minimum will contain the following information:

• Your name/seller ID/relevant VAT number
• Amazon/relevant VAT number
• Sales price (taxable base)
• Product taxability code (what VAT rate is applicable: low/high)
• The applicable VAT rate
• The applicable VAT amount

Where can I find information regarding my commingling transactions?

You will find information regarding your commingling transactions in the following data sources:

• Seller payment: The related VAT credits and debits are reported in the seller payment reports under What events occurred during the statement period? – Commingling VAT and give you a clear overview of the corresponding payable/receivable VAT in each of the 7 European countries.
• Tax document library: All the invoices issued by Amazon can be downloaded in PDF format under the “Tax document library”. In case you notice a certain irregularity in your invoice, we advise you to contact Seller Support. However, given that the data has been retrieved from the data inserted in your account setting, we advise you to verify your data as well to ensure that it is correct and up to date.
• Amazon VAT Transactions Report: The Amazon VAT Transactions Report provides detailed information for commingling transactions. Visit this page in case you have any further in-depth questions related to the AVTR.

Are my commingling transactions having an impact on the Distance Sales regime?

We would like to differentiate between two situations:

• In case you already charge VAT on your distance sales in the country of arrival (either because you exceeded the distance selling threshold for this country or because you opted to charge VAT in this country), the commingling program should not impact the applicable country VAT rate.
• In case you charge VAT on your distance sales in the country of departure (as you have not exceeded the distance selling threshold for the country of arrival and you have also not opted to charge VAT in this country), the applicable VAT rate is based on the actual ship-from country. As a PANEU FBA seller, you allow Amazon to store goods in, and fulfil goods from European countries (UK, Germany, France, Italy, Spain, Poland, and the Czech Republic). Therefore, shipments to consumers can happen from all 7 of these countries and then will be subject to country of departure VAT. The commingling program might (further) increase the number of shipments from one or more European countries.

To verify all tax consequences for your specific situation, we advise you to consult your tax advisor.