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Businesses may have a commercial interest in relocating part of their stock as close as possible to their customers. This relocation can take different forms: advanced stock, consignment stock, call-off stock, etc.

In an intra-EU context, this operation must be processed in two phases (transfer of own goods followed by a local sale) and generates a VAT registration for the supplier in the country where the stock is situated.

Many countries have adopted VAT simplification rules to avoid the need for the supplier to register for VAT for this type of transaction. The VAT rules differ from one country to another and create legal uncertainty for companies. To put an end to this cacophony, the European Council, at the instigation of the EU Commission, has decided to introduce new simplification rules on call-off stock arrangements from January 01, 2020.

The result, outcome of a bitter compromise, is not living up to expectations.