VATNIEU4830 - Transfers of own goods: movements of trading stocks: call-off stock
Call-off stock refers to goods transported by a supplier from a state of origin to a state of destination. At the time of the transport of goods, the supplier already knows the identity of the person to whom these goods will be supplied (called off) at a later stage and after they have arrived in the state of destination. That person is referred to in this guidance as ‘the customer’.
There are special rules for accounting for call-off stock if certain conditions are met. These are set out in VATNIEU4900. Where those conditions are not met the treatment of call-off stocks varies between states. Some treat the removal as a transfer of own goods. The UK interpretation relies on the customer acquiring the right to dispose of the goods as owner in the sense that the customer can use the goods as they wish subject to paying for them at that stage. Therefore, a UK customer receiving goods in Northern Ireland in these circumstances from a supplier in an EU member state, should account for VAT on acquisition on the basis of the movement of the goods even though title may not pass until they are ‘called off’. Accounting for acquisition tax cannot be delayed until the customer uses or ‘calls-off’ the goods.
Similarly, a UK supplier may zero-rate their supply of call-off goods to a customer in a member state, subject to the normal rules.
This only applies to goods that are intended for use by the one customer (i.e. where the customer uses the goods in their business or sells the goods on to their own customers as part of their taxable activities). Stocks used to supply more than one customer must be treated in the same way as consignment goods. Similarly, goods delivered to storage facilities operated by the supplier, rather than the customer, should also normally be treated as consignment stocks. However, they may be treated as call-off stocks if they are for the sole use of the same customer and that customer is made aware of the details of each delivery into storage.
Not all member states treat call-off transactions in the same way. So, UK businesses supplying call-off goods to customers in a member state may be required to register for VAT there. Businesses in this position should seek advice from the tax authorities in the member state concerned. VATNIEU1100.