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HMRC internal manual

VAT Single Market

HM Revenue & Customs
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Transfers of own goods: movements of trading stocks: call-off

Treatment of call-off stocks varies between Member 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 they can use the goods as they wish subject to their paying for them at that stage. Therefore a UK customer receiving goods in these circumstances from a supplier in another 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 they use or ‘call-off’ the goods.

Similarly, a UK supplier may zero-rate their supply of call-off goods to a customer in another 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 them in their business or sells them 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 other Member States may be required to register for VAT there. Businesses in this position should seek advice from the tax authorities in the Member State concerned. Contact details can be found on the website referred to at VATSM1100.