Reverse Charge & “Call Off Stock” in Slovenia
A call-off stock arrangement involves a supplier moving inventory to a storage location or warehouse, where a specifically designated customer has the ability to access and retrieve it as needed. Often, this warehouse or storage facility is owned or under the control of the customer.
In the context of foreign suppliers sending goods to Slovenia under consignment or as call-off stock, they are generally obligated to register for VAT in Slovenia. This requirement typically applies in most scenarios where goods are transferred into the country for such purposes.
Read more about Reverse Charge and “Call-off stock” in Slovenia in our comprehensive guide below.
When the reverse charge mechanism is applied to a supply, the customer is responsible for reporting and paying the VAT. The reverse charge mechanism is typically used for inbound business-to-business services provided by a taxable person not established in Slovenia, and Slovenia is the place of supply under Article 76 of the VAT Act.
Additionally, a domestic reverse charge applies to certain supplies, such as construction services related to immovable property, supplies of staff in connection with those services, supplies of certain immovable property, recyclable waste and scrap material, and the transfer of greenhouse gas emission allowances, under Article 76a of the Slovenian VAT Act. If the reverse charge applies to a supply, the supplier is not required to report or pay the VAT.
Selling in Slovenia?
Slovenia – Call off stock
A call-off stock arrangement refers to the transfer of stock by a supplier to a warehouse or storage facility, where it is held for a pre-identified customer who can retrieve it at any time. In many cases, the customer has ownership or control over the warehouse.
When foreign suppliers transport goods to Slovenia as consignment or call-off stock, they are generally obligated to register for Slovenian VAT.
Foreign consignors who transfer consignment stock to Slovenia are typically categorized as imports or intra-Community acquisitions, followed by a domestic supply to the end consumer. This requires the submission of a report.
Under certain conditions, suppliers of call-off stock registered in EU Member States may be eligible to eliminate the registration requirement through a simplification scheme. Different simplification strategies apply before and after January 1, 2020.
Schemes
Starting from January 1, 2020, one of the “Quick Fixes” introduced by Article 17a of the EU VAT Directive, which is implemented in Slovenian legislation through Article 9a of the Slovenian VAT Act, brings harmonization to call-off stock arrangements within the EU.
Under Article 9a, if a supplier transfers goods to a warehouse located in another EU Member State for the purpose of subsequent supply to a known purchaser, specific provisions apply. The transfer of goods to the warehouse is not considered a taxable event under the simplification rule. The taxable event occurs when ownership of the goods is subsequently transferred to the recipient. This taxable transfer is treated as a zero-rated intra-Community supply of goods from the supplier to the purchaser, as well as an intra-Community acquisition in the Member State where the purchaser is located. Consequently, the supplier is no longer obliged to register for VAT in the Member State of destination.
Last Updated: 22/12/2023
Disclaimer
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
