Transfer of goods to call-off stocks, instructions for filling in the form
Transferring goods to call-off stocks means that goods are moved to another EU country and stored in a warehouse owned by the buyer or a third party and where the buyer of the goods can claim them later.
As of 1 January 2020, you must file a report to the Tax Administration whenever you transfer goods to call-off stocks. File the report for the month when you began the transportation of the goods. The Tax Administration will send the details you have filed electronically to the EU country where the goods are delivered.
According to the Value Added Tax Act, you must file a VAT recapitulative statement (Form 9633e) to give details on your transfers of goods to call-off stocks. In practice, however, these details are submitted on this separate call-off report (Form 9634e). You can file the call-off report on paper only if there is a special reason, for instance if electronic filing is impossible due to technical difficulties.
Transferring goods to a call-off stock is not an intra-Community sale
As of 1 January 2020, the transfer of goods following the call-off stock procedure can no longer be considered comparable to sales of goods in the country where the goods are transferred from. This means that when you transfer the goods to the call-off stock, it is not yet considered supply of goods against payment. The intra-Community supply and acquisition only take place when the ownership of the goods passes on to the buyer.
Do not report the intra-Community sale on a VAT return until after the change of ownership. Report the sale as before on the VAT return and on the recapitulative statement.
When the buyer claims the goods from the call-off stocks in the country where the goods are transferred to, they report the intra-Community acquisition as normal.
The goods must be handed over to the buyer within 12 months from the transfer to call-off stock, unless the goods are returned or unless the buyer is substituted during this time. You must also file a call-off report if the goods are returned or if the buyer of the goods changes.
If the goods are not handed over to a buyer by the deadline, the sale is considered to have taken place on the day after the end of the 12-month time limit. In this case, the transferor of the goods must find out whether they are required to register for VAT in the country where the call-off stock is located. In addition, you must keep a list on the transfers.
When and how to file?
The call-off report is only for reporting the fact that goods have been transferred. The report does not include a specification of the type or quantity of the goods.
File the call-off report for each month when you transferred goods. You must report all transfers made during the month by the 20th of the following month. For example, if you have transferred goods in September, the deadline for filing the call-off report is 20 October.
You only need to file the report for the months when transfers to call-off stocks in another EU country were carried out.
You must report the following:
- new transfer of goods to call-off stocks or a new buyer entry (code 1)
- goods are returned or an incorrect entry is deleted (code 2)
- substitution of buyer (code 3).
You can also file in the Ilmoitin.fi e-service or via TYVI operators.
You can file on paper only if there is a special reason, for instance if electronic filing is impossible due to technical difficulties.
How to report transfers of goods
If you are reporting a new transfer, enter the buyer’s VAT number in field 1 (New transfer of goods to call-off stocks).
Example 1: On 21 January 2020, you transfer goods to a call-off stock owned by buyer S in Spain.
This transfer must be included in the call-off report for January. File this call-off report by 20 February. Record the transfer in your list of transfers. The buyer must also record the transfer in their list.
Example 2: On 24 February 2020, buyer S in Spain claims some of the goods stored in the call-off stock. You send an invoice to S in the same week.
You must report this intra-Community sale in the VAT recapitulative statement for February. Buyer S reports this transaction as an intra-Community acquisition in Spain. Note that because some of the goods have been claimed by the buyer, the quantity of goods stored in the call-off stock changes. Record this change in your list. The buyer must also record the change in their list.
Example 3: On 21 January 2021, more than 12 months have passed since the goods were transferred to the call-off stock, but buyer S in Spain has not claimed ownership of all the goods in the warehouse. The first day of the 12-month period is 22 January 2021, the day following the day in which the arrival of the goods took place.
An intra-Community sale of the remaining goods is considered to take place on the day after the 12-month period ends, i.e. 23 January 2021. You will have to report the sale on the VAT recapitulative statement for January 2021. You must submit a report on it in the same way as on transfers of business assets, as an intra-Community sale in Finland and an intra-Community acquisition in Spain. Find out if your company is required to register for VAT in Spain.
Read more about reporting transfers of business assets in finnish: VAT treatment of EU commerce of goods (Chapter 7 Transfer of business assets)
Report any returned goods
If the goods are returned back to you from the call-off stock, enter the buyer details you have previously reported in field 2 (Goods returned). File these details in the report for the month during which you received the goods back. You must file the report even if only a part of the goods were returned.
Example 4: You have transferred goods to buyer S’s warehouse in Spain also on 11 May 2020 and filed a call-off report on the transfer. Some of the goods are sold as intra-Community sales as in example 2 above. The rest are returned to you on 14 September 2020, before 12 months have passed since the transfer.
In the call-off report for September 2020, enter S’s VAT number in field 2 (Goods returned).
Record all the transfers in your list of transfers. The buyer must also record the transfers in their list.
If the goods were returned in the same month as when they were transferred to the call-off stock, enter the transfer and the return on separate rows. Enter the transfer in field 1 and the return in field 2.
Do not file a call-off report if the goods are returned after the change of ownership has taken place, i.e. after the intra-Community sale and acquisition have taken place. In these cases, you must make corrections to the VAT recapitulative statement you have filed on the sales.
Errors in the report
If you have reported something incorrectly – such as a wrong VAT number or a wrong month – you must make a correction to your call-off report.
- If you have entered the buyer’s VAT number incorrectly, file a new report for the same reporting month. Enter the incorrect number on its own row in field 2 (Deleting a previous entry). Enter the correct VAT number on its own row in field 1 (New transfer of goods to call-off stocks).
- If you have filed the report for a month when you did not have anything to report, file a new report for that month. Fill in the incorrect details you filed previously in field 2 (Deleting a previous entry).
- If you gave the buyer’s details correctly but the reporting month was incorrect, first delete the incorrect entry: enter the same month as previously, but enter the buyer’s details in field 2 (Deleting a previous entry). Then file a new report for the correct month: enter the correct month on the report and enter the buyer’s details in field 1 (New transfer of goods to call-off stocks).
Example 5: On 21 February 2020, you have transferred goods to buyer N´s warehouse in the Netherlands. In May 2020, you notice that you have accidentally entered buyer S in Spain as the recipient of the transferred goods. This means that you have reported incorrect buyer details for February 2020.
File a new call-off report for February 2020. To delete the incorrect information on S as the recipient, enter S’s VAT number in field 2 (Deleting a previous entry). Enter N’s VAT number on its own row in field 1 (New transfer of goods to call-off stocks). Make sure that the buyer details are recorded correctly in your list of transfers to call-off stocks.
Example 6: In May 2020, you have transferred goods to a call-off stock to buyer R in Sweden. However, you accidentally filed this transfer in the call-off report for February.
To correct this, file a new report for February and enter R’s VAT number in field 2 (Deleting a previous entry). You must also file a new call-off report for May. In the report for May, enter R’s VAT number in field 1 (New transfer of goods to call-off stocks). Make sure that the buyer details are recorded correctly in your list of transfers to call-off stocks.
Substitution of the buyer
If the original buyer is substituted by another buyer, report this change in the call-off report for the month when it took place. On the same row of the report, enter the new buyer in field 1 (New transfer of goods to call-off stocks) and the buyer you had previously reported in field 3 (Substitution of the buyer: buyer reported previously). Report these details in the same way if the buyer changes during the month when the goods were originally transferred to the call-off stock. Enter the details in the same way regardless of whether the substitution of the buyer concerns the entire lot of goods or just some of them.
Example 7: In example 1, you had transferred goods to buyer S in Spain. The transfer took place on 21 January 2020 and you filed a call-off report on the transfer for the 1/2020 reporting month. On 20 April 2020, these goods are transferred to another warehouse, operated by another buyer E and also located in Spain. All the requirements of the call-off procedure are still met.
Report the substitution of the buyer in your call-off report for the month 4/2020. Enter the VAT number of S, the original buyer, in field 3 (Substitution of the buyer: buyer reported previously) Enter the VAT number of the new buyer E in field 1 (New transfer of goods to call-off stocks). Since you are reporting a substitution, you must enter the buyer details on the same row. You must also record the changes in your list of transfers. Both buyers must also record the transfers in their lists.
If the goods are transferred to another recipient in a way that does not meet the requirements of the call-off procedure, a VAT recapitulative statement must be filed on the transfer in the same way as for transfers of business assets. The transferor must also find out whether they are required to register for VAT in the country where the goods are located. If the goods are sent or delivered from the original call-off stock to another EU country, the requirements for the call-off procedure are no longer met.
Example 8: In example 5, you transferred goods to buyer N in the Netherlands on 21 February 2020 and filed a call-off report on the transfer. However, after you have transferred the goods to the Netherlands, you transfer them directly to buyer B’s warehouse in Belgium. You sell some of these goods directly to buyer G in Belgium.
You must contact the authorities in the Netherlands and ask if you will be required to file a VAT recapitulative statement there, since you are selling goods from the Netherlands to Belgium.
What if I file late?
If you file the call-off report late, or if you do not file it at all, you may have to pay a negligence penalty. The negligence penalty is between €100 and €200. Read more about negligence penalties (in Finnish)
Requirements for the call-off stock procedure
The transfer of goods to a call-off stock in another EU Member State is not considered a sale if the following requirements are met:
- The transferor, i.e. the seller of the goods (or a third party on their behalf), sends or delivers the goods to a call-off stock in another EU Member State to a taxpayer who has the right to claim ownership of the goods. This right must be based on an agreement made between the seller and the buyer.
- The transferor’s business is not domiciled in the country where the call-off stock is located, and the transferor does not have a permanent establishment there.
- The buyer has registered for VAT in the country where the call-off stock is located, and the transferor already knows the buyer’s identity and VAT number before the goods are transferred.
- The transferor keeps a list of the goods they transfer and files a call-off report on the transfer.
If circumstances change and these requirements are no longer met, the call-off procedure is considered to have lapsed, and the transfer is treated as an intra-Community sale. If this happens, you will have to file a VAT recapitulative statement on the goods.
If the goods are destroyed, lost or stolen, the call-off procedure will lapse. The procedure is then considered to have lapsed on the date when the goods were stolen or destroyed. If this date is not known, the procedure lapsed on the date when it became apparent that the goods are destroyed or lost.
- VAT treatment of EU commerce of goods (in Finnish)
- Instructions for companies that are located in another EU country and are transferring goods to call-off stocks in Finland: Registering a foreign company for VAT in Finland
- Guidance on what information the seller and buyer must include in their lists: Council Regulation 282/2011 to promote harmonised interpretation of the VAT Directive (in Finnish)