Commingling allows Amazon to fulfill orders using identical products from different sellers. Doing so enables us to process a customer order more efficiently and expedite delivery from the fulfillment center that is closest to the buyer.
By using virtual tracking with the manufacturer barcode, we can trace the source of eligible products throughout the fulfillment process, despite the virtual transfers of ownership that commingling entails.
These virtual transfers of ownership can occur either locally in one country (domestic commingling) or cross-border in the EU (cross-border commingling). Additional seller eligibility requirements apply for cross-border commingling.
Your eligible products with the manufacturer barcode can be commingled domestically if valid VAT numbers are provided in the countries where the inventory is stored.
To participate in cross-border commingling, you must be enrolled in Pan-European FBA or Fulfillment Network Expansion (Central Europe Program). Additionally, you must provide valid VAT numbers to Amazon in at least two of the following countries: the UK, Germany, France, Italy, Spain, Poland, and the Czech Republic.
Commingling can occur only in or between the countries for which you provide a valid VAT number.
VAT, in the EU 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 EU and the UK. For more information, go to our VAT Knowledge Center or consult your tax advisor.
Yes. Commingling is a virtual transfer of ownership of products between two sellers and qualifies as a supply of goods for VAT purposes in the countries involved in the transfer (two countries for cross-border commingling, one country for domestic commingling).
When a product is commingled, Amazon will issue two additional invoices to record the virtual transfer of inventory. These additional invoices are generated monthly and show the aggregated commingled transactions per country.
Input VAT is the VAT mentioned on your incoming invoices from Amazon. Usually, input VAT is deductible, but we recommend that you consult with your tax advisor if you have questions.
Your offer price for the listing in the store where the item is sold will be used 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 same product from the other seller.
If you’re enrolled in Amazon’s VAT Calculation Service, Amazon will take the product tax code (PTC) that you have assigned to your offer and use the corresponding VAT rate. If you haven’t activated the VAT Calculation Service, Amazon will assign the product tax code and corresponding VAT rate.
If the product is acquired from another FBA seller or from Amazon Retail, we will use the product tax code assigned by Amazon.
In principle, sellers should charge VAT due on the supply of goods and pay this VAT to the tax authorities. In certain countries (the Czech Republic, France, Italy, Poland, and Spain) and in certain cases (depending on where your company is established or registered), 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 must report the VAT due in their VAT return but can deduct this amount in the same VAT return (generally no cash-flow impact).
In the case of commingling, a local reverse-charge mechanism may apply:
In principle, you always must have a VAT registration in the country where you hold inventory.
Commingling transactions can take place only if you have a valid VAT number in the country or 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 proceed only if a valid VAT number in both countries is provided.
Go to the VAT/GST registration numbers page and enter your available VAT numbers by country.
When you prepare your VAT reporting, treat these commingled transactions 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 the report. Therefore, make sure that you correctly calculate your final VAT position.
For more information, go to Amazon VAT Transactions report FAQ.
By default, the supplier is required to issue a VAT-compliant invoice to the 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 sellers.
For commingling transactions, Amazon issues a self-bill invoice for all the sales of products to another 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 can find information about your commingling transactions in the following data sources:
If 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 affect the applicable country VAT rate.
If you charge VAT on your distance sales in the country of departure (because you have not exceeded the distance-selling threshold for the country of arrival and you have not opted to charge VAT in this country), the applicable VAT rate is based on the actual ship-from country.
As a Pan-European FBA seller, you allow Amazon to store goods in and fulfill order from European countries (the UK, Germany, France, Italy, Spain, Poland, and the Czech Republic). Therefore, deliveries to buyers can happen from all seven of these countries and then are subject to country-of-departure VAT. Commingling might increase the number of deliveries from one or more European countries.
To verify all tax consequences for your situation, we recommend that you consult your tax advisor.