Call-off stock is a simplified VAT regime in which a supplier moves goods to a warehouse in another EU member state for a pre-agreed customer and accounts for the tax only when the customer actually takes the goods from the warehouse. As a result, the supplier does not have to register for VAT in the country where the warehouse is located.
What call-off stock is and what problem it solves
When a business moves its own goods to another member state, this is ordinarily treated as a transfer of own goods. For VAT purposes it counts as an intra-community supply to oneself in the country of dispatch and an acquisition in the country of arrival. The consequence is awkward: the supplier would have to register for VAT abroad, file returns there and declare the acquisition. For goods that sit in a customer’s warehouse and are sold only later, that would mean pointless foreign administration.
Call-off stock solves exactly this. It is a single rule introduced across the entire European Union on 1 January 2020 as part of the so-called quick fixes. In Slovakia it is governed by Section 8a of the VAT Act (Act No. 222/2004 Coll.) where Slovakia is the country of dispatch, and Section 11a where goods arrive in Slovakia; in the Czech Republic the equivalent is Section 18 of Act No. 235/2004 Coll. The essence is the same everywhere: moving the goods into the warehouse is not yet a taxable event — that occurs only when the customer takes the goods.
Which conditions you must meet
The simplification is not automatic. The law requires several conditions to be met at the same time, and breaching just one causes the regime to fall away:
- there is an agreement on a future supply of the goods between supplier and customer before transport begins — the customer is a specific buyer, not an anonymous market;
- at the time of dispatch the supplier knows the customer’s identity and VAT number assigned in the destination state;
- the supplier has no seat or fixed establishment in the warehouse state and is not registered for VAT there;
- the supplier keeps a dedicated register of the moved goods and reports the movement in the recapitulative statement.
If you want the wider context of invoicing across borders, see our article on how to invoice abroad from a VAT perspective, and the overview of mandatory invoice elements in Slovakia and the Czech Republic.
How the 12-month deadline works
Call-off stock is not open-ended. The law states that the transfer of the right to dispose of the goods as owner must take place within 12 months of the end of the transport to the warehouse. While the goods sit in the warehouse awaiting collection, nothing happens for VAT purposes. Only when the customer takes the goods does the supplier declare an intra-community supply exempt from tax, and the customer declares the corresponding acquisition in its own state.
Example: a Slovak company ships components in March to a warehouse in Germany for a German manufacturer that has agreed to draw them into production over time. As long as the manufacturer takes all the goods within 12 months, the Slovak company has no registration duty in Germany — it reports the taxable supply at home only in the month the collection actually took place.
What happens if the conditions stop being met
If the goods are not taken within 12 months and remain in the warehouse, the simplification ends. On that day the movement is treated as a transfer of own goods, and the supplier falls into the position where a registration and acquisition duty arises in the warehouse state. The regime equally fails if the goods are supplied to a different customer than the one in the original agreement, if they are dispatched to another state, or if they are lost or destroyed.
The law also provides a safety-net rule: if the original customer drops out but is replaced within 12 months by another pre-identified customer meeting the conditions, call-off stock may continue. The supplier must capture the change in its register and in the recapitulative statement.
How the regime is reported
Call-off stock has its own reporting rules. The supplier records the movement of goods in the recapitulative statement with the VAT number of the intended customer and a special code showing that this is not a classic supply but a transfer into the warehouse. The taxable supply itself is then reported in the recapitulative statement only in the period when the customer takes the goods.
A detailed register of the goods is also essential — value, quantity, date of movement, identification of the customer and any changes. The tax authority can thus verify at any time whether the goods in the warehouse still meet the conditions and whether the 12-month period has not expired.
How call-off stock differs from an ordinary consignment warehouse
In practice the terms call-off stock and consignment warehouse are often confused. A consignment warehouse is a commercial concept — a store from which a customer draws goods as needed and pays only for the quantity taken. Call-off stock, by contrast, is a precisely defined tax regime with specific conditions. Not every consignment warehouse meets the call-off stock conditions: if, for instance, the customer is not known in advance or the supplier is registered in the destination state, the simplification cannot be used and the standard transfer-of-goods rules apply.
Are you considering moving goods to a warehouse in another EU state and unsure whether to use call-off stock or to register abroad? We will gladly set up your cross-border model so that you avoid needless administration and penalties.
FAQ
Do I have to register for VAT abroad under call-off stock?
No — that is the main benefit of the regime. If all conditions are met (a pre-identified customer, their VAT number, no seat or registration of the supplier in the warehouse state, a proper register and recapitulative statement), no foreign registration arises. The customer accounts for the tax in its own state when it takes the goods. Registration would arise only if the regime ceased to apply.
By when must the customer take the goods from the warehouse?
Within 12 months of the end of the transport to the warehouse at the latest. If the customer does not take the goods within this period and they remain in the warehouse, the simplification ends and the supplier incurs a duty to register and declare a transfer of own goods in the warehouse state. The period is tracked separately for each consignment, which is why an accurate register matters.
What happens if the original customer changes?
The regime does not automatically collapse. If the original customer drops out but is replaced within 12 months by another pre-identified customer meeting the conditions, call-off stock may continue. The change must be recorded in the register and reflected in the recapitulative statement. If the goods are supplied to someone who does not meet the conditions, the simplification is lost.