Reverse Charge & “Call Off Stock” in Estonia

A “call-off stock” refers to a situation where goods owned by a non-resident supplier are sent to the customer’s country and stored there. Typically, these stocks are stored in the customer’s warehouse or facility, allowing the customer to have access to and withdraw supplies as needed. The act of withdrawing the stocks signifies the transfer of ownership of the goods.

Read more about Reverse Charge and “Call-off stock” in Estonia in our comprehensive guide below.

VAT guide Estonia

Reverse Charge in Estonia

The reverse charge refers to a mechanism whereby the recipient of the goods or services rather than the supplier is liable for VAT. The reverse charge applies upon an Estonian taxable person acquiring goods or services from a non-Estonian entity that is not registered for VAT in Estonia.

Reverse Charge Mechanism, according to the Estonian VAT Act, is applicable in Estonia. This mechanism can occur when the following requirements are met:

  • The acquirer must be a taxable person in Estonia.
  • There transaction must be either an acquisition of goods or a receipt of services.
  • The supplier must be a foreign taxable person that’s not registered in Estonia.
  • The supplier must not have a fixed establishment in Estonia.

Due to the implementation of the reverse-charge mechanism, the tax burden of the supplier is transferred to the recipient of the supply. As a result, the recipient becomes responsible for calculating the VAT amount applicable to the transaction. The recipient must account for both the output tax (tax charged) and input tax (tax paid) in their VAT returns. The input tax can only be deducted to the extent that it offsets the output tax, thereby determining the VAT due for the transaction. It’s important to note that the reverse-charge mechanism does not impact the amount of VAT due; it is reported solely for the purpose of VAT compliance.

Local reverse charge

The provision for the Local Reverse Charge mechanism can be found in Section 3(4) of the Estonian VAT Act. According to this section, the Local Reverse Charge mechanism is applicable when a transaction involves two taxable persons who are both registered for VAT in Estonia.

The scope of the Local Reverse Charge mechanism includes certain goods such as investment gold, precious metals, scrap metal, and real estate. Additionally, it also extends to specific supplies of metal products used in construction and engineering, such as sheet metal and beams.


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Estonia – “Call off stock”

Previously, before the simplification, the call-off stock scheme required the supplier to be VAT registered in Estonia. This allowed the transfer of goods to the warehouse to be treated as a transfer of the supplier’s own goods, which would then be reported as Intra-community Transaction.


Simplifying the EU’s call-off stock regime

Since January 2020, several EU Member States have implemented a simplification of the call-off stock requirements. As a result of this simplification, the previous registration requirement for EU member states is no longer applicable. Therefore, the supplier is not required to be VAT registered in Estonia in order to report the transfer as intra-community transactions.

The transfer of goods to the customer’s facility is no longer treated as a taxable event. However, the subsequent transaction, which occurs when the goods are needed and supplied to the customer, is considered a zero-rated taxable transaction. This transaction is categorized as a “direct” intra-community transaction. The supplier is responsible for reporting the Intra-Community Supply of Goods at a zero tax rate, while the customer records it as an Intra-Community Acquisition of Goods.


The transaction will be treated as “Quick Fixes” or Simplified Call-Off Stock when the following requirements are met:

  • The supplier of goods, including representatives or third parties, must be a taxable person.
  • The supplier must not have a permanent establishment in Estonia.
  • The receiver of the goods must also be a taxable person.
  • The supplier must possess the identity and VAT identification number of the receiver of the goods.
  • The supplier of goods must allow the tax authority to verify the “call-off stock” transaction when necessary.
  • The supplier is obligated to report the intra-community supply of goods in the EC Sales Listing (ESL), which should include the identity and VAT registration of the receiver.
  • The supply of goods must take place within twelve months from the arrival of the goods in Estonia.


Call-Off Stock Register

Both the supplier and the receiver of goods must maintain a register with specified information. This is mandated by Article 5a of EU Implementing Regulation 282/2011.

It is mandated that the supplier’s register must contain the following:

  • The country where the goods are from and the date of dispatch.
  • The VAT registration of the receiver.
  • The country of arrival, VAT registration number of the warehouse keeper, address, and date of arrival.
  • The amount, description, and quantity of goods.
  • The taxable amount, description, and quantity of goods subsequently supplied and the date of transfer of ownership.
  • VAT registration number of the buyer.

On the other hand, the receiver’s register must contain the following:

  • The VAT registration number of the supplier.
  • The description and quantity of the goods intended for the subsequent receiver.
  • The arrival date of the goods.
  • The taxable amount, description, and quantity off the goods supplied and the date of the subsequent transfer.

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Estonia – Import VAT

In the context of VAT, the term “import” pertains to a transaction in which goods are procured from a jurisdiction outside the EU VAT area and moved into a Member State, such as Estonia, either directly or via another Member State. As a general rule, imports of goods and inbound services are subject to Estonian VAT.


Import VAT is imposed by Customs on items imported from non-EU countries. The taxable value of the imported goods includes the customs value based on the Union Customs Code and all applicable import duties. This value determined by customs legislation may be subject to adjustments. Additionally, any transport costs incurred up to the first destination within the territory of Estonia, which may not be included in the customs value, are also considered part of the taxable value.


The time of supply for imported goods is when the goods are cleared from customs. In order to deduct input tax, a customs declaration supporting the imported goods must be provided.


Imports in general

The term “import of goods” generally refers to several scenarios, including:

  • The act of placing non-Community goods under the customs procedure of release for free circulation.
  • Applying the temporary importation procedure with partial relief from import duties, or the inward processing procedure utilizing the drawback system.
  • Include the act of placing goods subject to the outward processing procedure under the customs procedure of release for free circulation.
  • Any other cases that result in a customs debt within the meaning of the Union Customs Code may also qualify as an import of goods.


Relief from Import VAT

For Estonian VAT purposes, certain supplies are relieved from the import VAT. Examples of these are the following:

  • Imported golds by the Central Bank of Estonia (Eesti Pank).
  • Exempt goods listed under the general rules.
  • Banknotes, coins, and revenue stamps.
  • Natural gas and electricity, as well as heating and cooling energy, are imported through networks, while gas is injected into natural gas networks using tankers.
  • Goods subject to immediate tax warehousing.
  • Tobacco and alcoholic products from a third country to Estonia carried by a passenger covered by the excise duty free limits provided.
  • Goods for non-commercial use (excluding tobacco and alcoholic products) carried by a passenger from a third country to Estonia amounting to EUR 300 (EUR 430 for air or sea travel). If exceeding the set threshold, the goods shall be subject to VAT in full.


Last Updated: 01/11/2023


The information provided by Global VAT Compliance B.V. on this webpage is intended for general informational purposes only. Global VAT Compliance B.V. is not responsible for the accuracy of the information on these pages, and cannot be held liable for claims or losses deriving from the use of this information. If you wish to receive VAT related information please contact our experts at support@gvc.tax

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