The situation
Goods moved to a customer’s warehouse in another member state and drawn down as needed
A German maker of cast aluminium housings in Regensburg has agreed to keep a buffer of stock at its largest customer’s assembly plant near Plzeň. The customer takes parts off the shelf as its lines need them and is invoiced monthly. Logistics wants to start in January. The head of tax wants a memo before the first truck leaves.
The simplification itself is well known. The hours go on the conditions around it: whether the German company has any establishment in the Czech Republic, what happens to parts still on the shelf after a year, what each side must record, and what goes on the recapitulative statement. Miss one and the company needs a Czech VAT registration.
What the research has to settle
The rules behind the answer
- Without the simplification, a local registration
- Moving your own goods to another member state is generally treated as an intra-Community supply by you and an acquisition in the destination country. Holding stock in the Czech Republic would then mean registering for VAT there.
- The four conditions
- The VAT Directive’s call-off stock rules apply when the goods are sent so that a customer can take them later under an existing agreement, the supplier has no business or fixed establishment in the destination country, the customer is identified for VAT there and known at the start of transport, and the supplier records the transfer.
- The 12-month clock
- The supply happens when the customer takes the goods. Goods not taken within 12 months of arrival are treated as transferred on the day after the period ends, and the registration question returns. Another customer can be substituted within the period, under conditions.
- Records on both sides
- The supplier keeps a register of goods sent under the arrangement and reports the customer’s VAT number on its recapitulative statement. The customer keeps a register of the goods it receives and takes.
How it runs in azta
From the question to the document
The question, as you would type it
German company will hold a stock of parts at a Czech customer’s plant. The customer is Czech VAT-registered and takes parts as needed; we have no Czech establishment. Does the call-off stock simplification apply, what records must each side keep, and what happens to parts still there after 12 months?
You start with
Goods moved to a customer’s warehouse in another member state and drawn down as needed
- 01
Ask the question with the facts
Describe the goods, the two countries, the customer and where your staff and equipment are. azta searches the VAT Directive and the German and Czech VAT acts.
Cited research· Free - 02
Read the conditions in the original
Open each cited provision in the reader, in German and in Czech, with its in-force status, and compare it with the Directive.
Atlas statute reader - 03
Check the stock agreement
Upload the agreement with the customer. azta checks it against each condition and points to the clause it relied on.
File upload· Pro - 04
Draft the memo
Ask for a memo with the conclusion, the conditions to keep in place and the 12-month control. Edit it in Canvas.
Canvas · Ask azta· Pro You send
A memo on whether the call-off stock simplification applies and what it requires
What you get
A memo on whether the call-off stock simplification applies and what it requires
Tax memo · draft
Stock at the Plzeň plant: call-off stock treatment
Conclusion. The planned arrangement can fall under the call-off stock simplification. The company would then make an intra-Community supply from Germany when the customer takes the parts, and would not need to register for VAT in the Czech Republic.
Conditions to keep in place. The customer must be identified for VAT in the Czech Republic and named, with its VAT number, before each shipment leaves Regensburg. The company must have no establishment in the Czech Republic. Each transfer is entered in our call-off stock register and reported on the recapitulative statement.
Parts not taken within twelve months. These are treated as moved to the Czech Republic on the day after the twelve months end, which would require a Czech registration. Logistics will report stock older than ten months each month so that it can be brought back or sold in time.
Outcomes on your numbers
What azta is worth on this task
Pro pays for itself after
13 minutes a month
At €130 an hour, that is all the time Pro (€27 a month) has to take off your desk to cover its price.
Example figures. Replace them with your own.
- Hours back a year
- 22
- Capacity at your rate
- €2,808
- More call-off stock memos a quarter
- 0.8
- Return on Pro
- 8.7×
- Research
- Drafting
- Your review
A scenario you set, not a promise. The hours that come back go to another client, or deeper into this one.
Want these numbers on your team’s real workload?
Book a demoWhat stays with you
- Confirming the company has no establishment in the Czech Republic, including staff or equipment at the customer’s plant.
- Monitoring stock age against the 12-month limit, which sits in your systems.
- Agreeing the register format and reporting with the customer.
Frequently asked questions
- Does azta hold the Czech tax authority’s guidance on this?
- It cites the Czech VAT act and the published decisions it holds, not every authority’s guidance. Each answer shows what it relied on, so you can see where guidance still needs checking.
- What if the customer changes during the year?
- Give azta the new facts. The rules allow another customer to be substituted within the 12 months under conditions, and the answer cites them.
- Can I review an arrangement that started years ago?
- Yes. Give the date and azta focuses on the law as it stood then.
