Commingling transactions are inventory swaps between two FBA (Fulfillment by Amazon) sellers, or between an FBA seller and Amazon Retail within the commingling program. 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.
Even though your inventory does not have additional labels, Amazon assigns a virtual trackable label to your units when they are received. Virtual trackable labels allow Amazon to keep a track of your inventory at all the times.
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.
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.
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).
By participating in the FBA commingling program, 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.
When a product is commingled, Amazon will issue two (additional) invoices to record the inventory swap:
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 reach out to your tax advisor in case of questions to obtain confirmation.
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 and contact seller Support.
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:
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 fulfillment centers 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.
Please visit the VAT/GST Registration Numbers page, and enter your available VAT numbers by country.
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 & Commingling_Buy transactions are shown as a positive value in your AVTR. Therefore, please make sure you correctly calculate your final VAT position.
For more information, please go to this page.
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:
You will find information regarding your commingling transactions in the following data sources:
We would like to differentiate between two situations:
To verify all tax consequences for your specific situation, we advise you to consult your tax advisor.