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Call-off stock: last dispatch on 30 June 2028, the regime closes in 2029

30 June 2028 is the last day on which goods may be dispatched under call-off stock arrangements; on 30 June 2029 the simplification ceases to apply. Directive (EU) 2025/516 sets both dates. From 1 July 2028 they are joined by the special scheme for transfers of own goods, the core of single VAT registration, and by the mandatory reverse charge in the rewritten Article 194. In Italy, meanwhile, the rules move to Articles 9 and 40 of the consolidated VAT act.

Two dates bring the call-off stock arrangements to an end: 30 June 2028, the last day on which goods may be dispatched under it, and 30 June 2029, the day on which the simplification ceases to apply. Both are set by Council Directive (EU) 2025/516 of 11 March 2025. They matter as much to a business that sends its own goods to a customer in another Member State as to one that receives goods in Italy from its foreign supplier.

Nothing has to be done immediately. What changes is the planning horizon: the deadline already bears on multi-year supply contracts and on logistics planning. A call-off stock agreement signed today that provides for dispatches in 2029 contains a clause that will have no legal basis on the date when it is meant to operate.

Why call-off stock exists

The general rule is burdensome. The transfer by a taxable person of goods forming part of its business assets from one Member State to another is treated, in the Member State of departure, as a supply of goods for consideration (Article 17(1) of Directive 2006/112/EC), and is matched by a corresponding intra-Community acquisition in the Member State of arrival. Under Italian law the deemed transfer is that of Article 41(2)(c) of Decree-Law No 331 of 30 August 1993, and the deemed acquisition the one in Article 38(3)(b) of the same decree. The practical consequence is local VAT identification in the Member State of arrival, with local returns, payments and accounting obligations, before the goods have even been sold.

The call-off stock simplification avoids that step. Article 17a of Directive 2006/112/EC is implemented in Italy by two mirror provisions: Article 41-bis of Decree-Law 331/1993 for goods leaving Italy and Article 38-ter for goods entering it. The first allows the dispatch of goods to an intended acquirer not to be treated as a deemed transfer, and postpones the intra-Community supply to the moment when ownership passes to that acquirer. Four conditions apply, and they should be read carefully because they are not all of the same kind:

• the goods are dispatched to another taxable person entitled to acquire them under an agreement existing between the two parties
• the supplier has neither established its business nor has a fixed establishment in the Member State of arrival
• the intended acquirer is identified for VAT purposes in that Member State, and its identity and VAT identification number are known to the supplier at the time the dispatch or transport begins
• the supplier records the transfer in the register provided for in Article 50(5-bis), and enters in the recapitulative statement under Article 50(6) the identity and VAT identification number of the intended acquirer

The first three conditions underpin the transaction; the fourth documents it. The fourth is a condition nonetheless, not a subsequent obligation: if the register is not kept or the statement is not completed, one of the preconditions in Article 41-bis(1) ceases to be met and the deemed transfer under Article 41(2)(c) occurs, with the local VAT identification in the Member State of arrival that the simplification was meant to avoid. When that deemed transfer takes place depends, however, on when the condition ceased to be met, and the distinction is not merely theoretical, because it determines the foreign tax period in which the transaction has to be declared: if the condition was not met from the outset, Article 41-bis(1) never operated at all and the transfer is placed at the time of dispatch; if the condition ceases to be met during the twelve months, Article 41-bis(3)(b) applies instead and places the transfer at the moment when the condition ceased to be met.

That qualification as a condition applies, however, only on the outbound side: Article 38-ter lays down three conditions, and the register of the person receiving the goods is a free-standing obligation whose breach is penalised but does not cause the arrangements to be lost. Nor, for the supplier, does the condition consist in the completeness of the register: the condition is to record the transfer and to enter the intended acquirer in the recapitulative statement, while keeping the register in full is a separate obligation. The content of the register, moreover, is not a matter of choice: it is set out in Article 54a of Implementing Regulation (EU) No 282/2011, which provides for one register for the taxable person transferring the goods — Member State and date of dispatch, VAT identification number of the intended acquirer, address of the warehouse, date of arrival and subsequent events — and one for the person receiving them.

The penalty regime has two aspects, and they should be kept apart. As regards formal obligations, failure to keep or preserve the register as prescribed carries a penalty of EUR 1,000 to EUR 8,000 (Article 9(1) of Legislative Decree No 471 of 18 December 1997), while an omitted, incomplete or inaccurate recapitulative statement carries EUR 500 to EUR 1,000 for each statement, halved if the statement is filed within thirty days of a request by the tax offices and not applied if the missing or inaccurate data are supplied or corrected, including in response to such a request (Article 11(4) of the same decree). The greater exposure, however, lies elsewhere: in the loss of the regime, with the tax and the penalties of the Member State of arrival.

The twelve-month period is a separate matter from the four conditions: it runs from the arrival of the goods and is the time within which ownership must pass to the intended acquirer. If it expires without that happening, the deemed transfer occurs in any event on the following day. That is not, however, the only event that breaks the regime: it is also broken where one of the conditions ceases to be met, where the goods are supplied to a different person, where they are dispatched to another State, and where they are destroyed, lost or stolen. The rules do, however, provide two ways out, which become the principal means as the regime is wound down: return of the goods to the Member State of departure within the twelve months, which gives rise to no intra-Community supply and must be recorded in the register; and substitution of the intended acquirer by another taxable person, again within the twelve months and again recorded.

The two dates that close the regime

Article 2 of Directive 2025/516, applicable from 1 January 2027, amends Article 17a itself. In paragraph 2, point (a), the Directive replaces the text so as to introduce a time limit: the goods must be dispatched or transported ‘on or before 30 June 2028’. It then adds a paragraph 8 to the same article: ‘This Article shall cease to apply on 30 June 2029’.

Recital 43 states the plan: since the new special scheme for transfers of own goods also covers the movements currently covered by the call-off stock arrangements, that regime is to be phased out by setting a date after which no new arrangement may begin, while arrangements already under way keep ‘the relevant conditions, including the 12-month deadline for the transfer of the ownership of those goods to the intended acquirer’. The regime is therefore not abolished overnight: it is closed by exhaustion.

The two dates, however, do not fit together perfectly, and the point deserves practical attention. The two time limits are tied to different events: the 30 June 2028 limit relates to dispatch or transport, whereas the twelve months run from the arrival of the goods. A consignment dispatched on 30 June 2028 and arriving ten days later would see its twelve months expire in July 2029, when Article 17a has already ceased to apply; and even in the extreme case of arrival on 30 June 2028 itself, the ‘day following expiry’ would fall on 1 July 2029, after the provision that lays it down has ceased to apply. Recital 43 points towards continuity, since it expressly preserves the twelve-month period for arrangements already under way; recitals do not, however, override the enacting terms, and the enacting terms of the new paragraph 8 fix the cessation at 30 June 2029. The point therefore remains open — the reading based on continuity is the one that gives the recital practical effect — and will have to be checked against the national implementing text and the guidance that follows. In the meantime the practical conclusion is plain: it is unwise to concentrate the last dispatches close to the deadline.

As regards documentary obligations, from 1 July 2029, Article 4 of the Directive deletes Article 243(3), namely the obligation to keep the register of goods under call-off stock arrangements, and Article 262(2), namely the obligation to report those goods in the recapitulative statements. As regards transposition, Member States are to adopt and publish the provisions necessary to comply with Article 2 by 31 December 2026, those relating to Article 3 by 30 June 2028 and those relating to Article 4 by 30 June 2029 (Article 6(2), (3) and (4) of the Directive).

What takes its place: the special scheme for transfers of own goods

From 1 July 2028, Article 3 of the Directive inserts a new Section 5 into Title XII, Chapter 6, of Directive 2006/112/EC, headed ‘Special scheme for transfers of own goods’ (Articles 369xa et seq.). It is the fourth One Stop Shop scheme, alongside the non-Union scheme, the Union scheme and the import scheme, and it is the first of the two pillars of what the EU legislature calls single VAT registration.

The intra-Community acquisition of the goods in the Member State to which they are dispatched or transported is exempt and, ‘without prejudice to Article 214(1)’, does not give rise to an obligation to be identified in that Member State; for the purposes of Articles 16, 18, 26, 185 to 189 and 192, the exemption is treated as the exercise of a full right of deduction. No new number is needed either: the Member State of identification uses the individual VAT identification number already allocated to the taxable person. The return is monthly, submitted by electronic means by the end of the month following the tax period even where no goods have moved, drawn up in euro using the European Central Bank exchange rate for the last day of the period, and broken down by Member State of departure and by Member State of arrival. Changes that become necessary after the deadline are included in a subsequent return, within three years.

The conditions for access deserve attention. The scheme is optional but not divisible: a taxable person registered for it must apply it to all of its transfers of own goods. Goods for which there is no full right of deduction in the Member State of arrival fall outside the scheme. The Member State of identification is determined as follows:

• for a taxable person that has established its business in the Union, it is the Member State in which the business is established
• for a taxable person that has not established its business in the Union but has a fixed establishment there, it is the Member State of that fixed establishment; where there is more than one fixed establishment, the choice is binding for the calendar year in which it is made and the two following calendar years
• for a taxable person that has neither established its business nor has a fixed establishment in the Union, it is the Member State of departure of the goods, and where there is more than one Member State of departure the same three-year rule applies
• for a taxable person already registered for the Union scheme, it is the same Member State as for that scheme

One point affects cash flow. Input VAT incurred in the Member States from or to which the goods are dispatched cannot be deducted in the return for the special scheme, but is recovered through the refund procedures laid down in Directive 2008/9/EC or Directive 86/560/EEC. The exception is where the taxable person is in any case identified in the Member State concerned for activities falling outside the scheme: in that case, deduction follows the ordinary return. A business that today deducts VAT on local logistics costs by virtue of its local identification must reckon with different recovery times. For the rates applicable in each country, our table of VAT rates in the EU Member States is a starting point.

A less visible effect concerns the exemption and the recapitulative statements, and it repays careful reading, because it works in the opposite direction to what might be assumed. A second subparagraph is added to Article 138(1), under which the condition in point (b) of the first subparagraph — the one requiring the person acquiring the goods to be identified for VAT purposes in a Member State other than the one in which dispatch or transport of the goods begins, and to have indicated that VAT identification number to the supplier — does not apply to transfers declared under the special scheme. This is not an exclusion from the exemption but the disapplication of a condition that could never be met under that scheme, since there is no identification at all in the Member State of arrival — which, for a transfer of own goods, is precisely the Member State other than that of departure: the transfer remains exempt under Article 138(2)(c). Those transfers do, however, fall outside the recapitulative statement under Article 262(1)(a), the replacement text of which expressly excepts the case where the special scheme is used: that is the answer to the question the move away from call-off stock arrangements leaves open, namely whether anything replaces today’s reporting of goods held under those arrangements: nothing does. Record-keeping obligations remain: documentation of the transfers must be kept and made available by electronic means, on request, to the Member State of departure, to the Member State of arrival and to the Member State of identification, and must be retained for ten years from 31 December of the year of the transfer. The scheme can also be lost: the Member State of identification excludes a taxable person who ceases to carry out the activity, who no longer meets the requirements, or who persistently fails to comply with the rules.

Lastly, there is a further obligation for businesses that move goods belonging to others: the new Article 242b requires a taxable person who transfers goods to another Member State on behalf of another taxable person to inform that other person, at the latest at the time of the dispatch or transport, where the transfer is not made at that person’s explicit request. It closely concerns logistics operators, and belongs in warehousing contracts before it becomes an obligation already missed.

The reverse charge becomes the rule

The other pillar of single VAT registration is the rewritten Article 194, which also applies from 1 July 2028. Where a taxable supply of goods or services is carried out by a taxable person who is neither established nor identified for VAT purposes in the Member State in which the VAT is due, the person liable for payment of the VAT is the person to whom the goods or services are supplied, provided that that person is already identified in that Member State. The reverse charge thus ceases to be an option left to Member States. Member States may still provide, under conditions which they lay down, for the reverse charge to apply to supplies made by any taxable person who is not established, whether or not identified. Supplies made by a taxable dealer where the goods are subject to the margin scheme are expressly excluded from that rule.

For an Italian reader the change is less striking than it may seem, and it is worth saying so: Article 17, second paragraph, of Presidential Decree No 633 of 26 October 1972 already places the obligations on the customer — the taxable person acquiring the goods or receiving the services — where that person is established in Italy, for supplies whose place of supply is Italy and which are made by non-resident persons, whether or not identified. The rewriting of Article 194 makes itself felt in the other Member States, and that is precisely why it matters to an Italian business with goods abroad.

The combined effect is what counts: moving goods to another Member State and selling them from there to customers who are taxable persons and already identified will no longer require, in itself, a local VAT identification. A foreign warehouse will no longer, by itself, be a reason for applying for a local VAT identification. The mandatory reverse charge presupposes, however, that the supplier is not identified in that Member State: a business that keeps a local VAT identification there, even solely in order to deduct input VAT on local costs, falls outside Article 194 and continues to charge local VAT on its sales, unless that Member State exercises the option, confirmed by the same provision, of extending the reverse charge to non-established persons who are identified: Italy has already done so, and the position must be checked country by country. There remains the case of supplies to persons who are not taxable persons. A sale from that foreign warehouse to a private individual is not an intra-Community distance sale — the goods do not cross a border; they are already there — but a domestic supply in that Member State, and the single EUR 10,000 threshold discussed in EU e-commerce: how the EUR 10,000 threshold changes from 2027 does not come into play. For those transactions too, however, there is an answer: from 1 July 2028 the Union scheme is also open to a taxable person not established in the Member State in which the goods are subject to VAT, who supplies goods to a taxable person or a non-taxable legal person whose intra-Community acquisitions of goods are not subject to VAT under Article 3(1) of the Directive, or to any other non-taxable person, where those goods are supplied without dispatch or transport, or where the dispatch or transport begins and ends in the same Member State.

Transposition in Italy

The first change has already happened, and it has nothing to do with the Directive. Articles 41-bis and 38-ter of Decree-Law 331/1993 have been repealed by Article 170(1)(s) of the consolidated value added tax act annexed to Legislative Decree No 10 of 19 January 2026, the repeal taking effect, under Article 171 of that consolidated act, on 1 January 2027. Today, therefore, they are still fully in force. The simplification does not disappear: it moves. In the consolidated act it is found in Article 40, ‘Intra-Union supplies under so-called call-off stock arrangements’, and in Article 9, ‘Intra-Union acquisitions under so-called call-off stock arrangements’, with the same conditions — four for supplies, three for acquisitions — and with the register relocated to Article 101(5). From 2027 it is those articles that contracts and internal procedures will have to cite.

The second change is under way. From 22 June to 6 July 2026 the Department of Finance of the Ministry of Economy and Finance held a public consultation on the draft legislative decree implementing Article 2 of the Directive; the Italian Council of Ministers, meeting on 4 August 2026, gave the draft its preliminary approval (esame preliminare) (press release No 185, issued on 5 August 2026). The press release describes provisions that ‘are mainly clarificatory in nature’ and lists platforms, portals and electronic marketplaces, the EUR 10,000 threshold, the coordination between the special VAT schemes and the special scheme for small enterprises, and the refund procedures: it says nothing about call-off stock. The press release, however, is a summary and not the enacting terms: its silence does not mean that the provision is absent from the text approved, which has not yet been published. The draft put out to consultation, by contrast, deals with call-off stock expressly. Its Article 2 inserts the words ‘by 30 June 2028’ into Article 38-ter(1)(a) and Article 41-bis(1)(a) of Decree-Law 331/1993, and provides that ‘Articles 38-ter and 41-bis are repealed with effect from 30 June 2029’. The correlation table accompanying the draft heads that item ‘Transitional regime and repeal of the call-off stock arrangements’.

Two questions remain to be settled in the final text. The first is one of coordination: the draft amends articles of Decree-Law 331/1993 that the consolidated act repeals from 1 January 2027, which is the very date from which the draft itself is to apply; unless the text as approved is carried over to Articles 9 and 40 of the consolidated act, the two sets of amendments will overlap. The second concerns a single day, but that day may count: the Directive says that Article 17a ‘shall cease to apply on 30 June 2029’, whereas the Italian draft repeals the articles ‘with effect from 30 June 2029’. On a deadline framed as ‘the day following expiry’, the difference decides which set of rules governs the event.

In practice

The useful work today is a review of existing arrangements. It is worth proceeding point by point:

• list the call-off stock arrangements in place, Member State by Member State, distinguishing outbound ones (Article 41-bis) from those in which the business receives another party’s goods (Article 38-ter), with the arrival date of the goods and the twelve-month deadline
• identify the contracts that provide for dispatches beyond 30 June 2028 and agree with the counterparty, in good time, what is to become of later consignments
• check, for outbound arrangements, that every transfer is recorded in the register and that the intended acquirer is entered in the recapitulative statement for the period, since these are conditions of the regime and not merely statistical obligations, and that substitutions of the intended acquirer and returns of goods have been recorded
• check in addition that the register contains all the information required by Article 54a of Implementing Regulation (EU) No 282/2011: that is a free-standing obligation, penalised in its own right
• plan the emptying of the warehouses before 30 June 2029, using the return of the goods or the substitution of the intended acquirer where necessary
• write into warehousing contracts the information obligation in Article 242b, which falls on a business transferring another party’s goods to another Member State otherwise than at that party’s explicit request
• check the decree implementing Article 2 as soon as it is published — it is expected by 31 December 2026 — and the new numbering in the consolidated act

As to the decisions to be taken, the choice to be examined is not so much whether to join the special scheme from 1 July 2028 as whether to keep a local VAT identification, because that is what determines the rest. The first route avoids multiplying foreign identifications, but it operates for the whole of a business’s transfers and moves the recovery of VAT on costs into the refund procedure; the second preserves immediate deduction but rules out the mandatory reverse charge under Article 194 and entails charging local VAT on sales, with the returns and payments that follow. The comparison is therefore not between immediate deduction and a multiplication of compliance obligations: it is between the mandatory reverse charge with input VAT recovered through the refund procedure, on the one hand, and immediate deduction with local VAT due on every sale, on the other. The choice depends on the number of Member States involved, on the amount of VAT incurred on local costs — worth quantifying country by country, since it is the item that decides the comparison — and on whether there are supplies to persons who are not taxable persons. For the general framework of the tax, see our practical guide to VAT.

Finally, it is worth documenting the decisions taken: the inventory of foreign warehouses, the notices to customers about the 30 June 2028 deadline, and any option exercised for the special scheme, with the date from which it takes effect. These are the items that, in an inspection, explain why a local VAT identification was applied for abroad, or why it was not.

Frequently asked questions

Are there any obligations already in 2026?

No new call-off stock obligation falls due in 2026. Two things do change, however: the contractual horizon, since agreements providing for dispatches after 30 June 2028 are to be renegotiated or supplemented with a clause governing the transition to the ordinary rules or to the new special scheme; and the statutory references, since from 1 January 2027 the rules are to be found in Articles 9 and 40 of the consolidated VAT act rather than in Articles 38-ter and 41-bis of Decree-Law 331/1993.

Does the new special scheme remove the need for a foreign VAT identification?

For transfers of own goods alone, yes: the intra-Community acquisition in the Member State of arrival is exempt and gives rise to no obligation to be identified. The transactions that follow are governed by their own rules: where the customer is a taxable person already identified and the supplier is not identified in that Member State, the mandatory reverse charge in Article 194 applies, while supplies from the foreign warehouse to persons who are not taxable persons are domestic supplies in that Member State and may, from 1 July 2028, be declared through the Union scheme. A local identification may therefore still be needed for other reasons — for instance in order to deduct VAT on local costs without going through the refund procedure; a business that keeps one, however, falls outside Article 194 and reverts to charging local VAT on its sales.

What happens to goods still held by the customer on 30 June 2029?

As the Directive envisages matters, there should be none, since the last permitted dispatch may take place on 30 June 2028 and the twelve months, which run from arrival, should expire by 30 June 2029. That design, however, takes no account of the gap between the date of dispatch and the date of arrival, and it is from arrival that the twelve months run: that is the open point noted above. If ownership has not passed by the deadline, the deemed transfer occurs in any event, but by two different routes depending on when the deadline falls: up to 30 June 2029 under the rule that already applies today, which places it on the day following expiry of the twelve months; after that date because, once Article 17a has ceased to apply, the derogation falls away and goods still held come under the general rule in Article 17(1). In either case, obligations arise in the Member State of arrival. Which of the two sets of rules governs an event straddling that date remains to be clarified in the national implementing text. Returning the goods or substituting the intended acquirer, while the regime still operates, remains the simplest way of not reaching that date with the warehouses full.

What should an Italian business receiving foreign goods under call-off stock expect?

This is the mirror image, and in practice it is the situation that arises most often. While the arrangements hold, the foreign supplier is not identified in Italy and the intra-Community acquisition arises for the Italian business at the moment it acquires ownership of the goods. If, however, the twelve months expire without ownership having passed, on the following day it is the foreign supplier that makes an intra-Community acquisition in Italy: from that moment it must be identified for VAT purposes in Italy or appoint a tax representative, and the subsequent sale to the Italian customer is no longer an intra-Community supply but a domestic one. For the Italian business the tax remains due in Italy, because Article 17, second paragraph, of Presidential Decree No 633 of 1972 places the obligations on the customer established in Italy; what changes is the legal characterisation of the transaction and the documents that accompany it. It is therefore worth monitoring the twelve-month deadline on inbound arrangements too: the loss of the arrangements is the supplier’s problem, but it is the customer who receives the invoice.

Sources

Council Directive (EU) 2025/516 of 11 March 2025 amending Directive 2006/112/EC as regards VAT rules for the digital age (Official Journal of the European Union, L series, 2025/516 of 25 March 2025), recital 43 and Articles 2, 3, 4 and 6; Council Directive 2006/112/EC of 28 November 2006, Articles 17, 17a, 138, 194, 214, 242b, 243 and 262 and Title XII, Chapter 6, Sections 3 and 5; Implementing Regulation (EU) No 282/2011, Article 54a; Decree-Law No 331 of 30 August 1993, Articles 38, 38-ter, 39, 41, 41-bis and 50; Legislative Decree No 10 of 19 January 2026, the consolidated value added tax act, annex, Articles 9, 40, 101, 170 (repeals) and 171 (entry into application); Presidential Decree No 633 of 26 October 1972, Article 17, second paragraph; Legislative Decree No 471 of 18 December 1997, Articles 9(1) and 11(4); Ministry of Economy and Finance, Department of Finance, public consultation from 22 June to 6 July 2026 on the draft legislative decree implementing Article 2 of Directive (EU) 2025/516, with the accompanying correlation table; Presidency of the Council of Ministers, press release of the Council of Ministers No 185 of 5 August 2026, concerning the meeting of 4 August 2026; Law No 36 of 17 March 2026 (European Delegation Law 2025), Article 1(1) and Annex A, No 13; European Commission, Directorate-General for Taxation and Customs Union, page on VAT rules for the digital age.