EU: Treatment of small losses of goods under call-off stock arrangements

EU: Treatment of small losses of goods

The VAT Committee—as set up under Article 398 of the VAT Directive to promote uniform application of the provisions of the VAT Directive—reached an agreement on the treatment of how to handle small losses under “call-off stock arrangements.”


The VAT Committee is an advisory committee and cannot make binding decisions, but it can give some guidance on the application of the VAT Directive.

According to a 12 March 2021 update to the VAT Committee’s guidelines [PDF 2.1 MB], small losses of goods under call-off stock arrangements (Article 17a of the VAT Directive) arising from the actual nature of the goods, from unforeseeable circumstances or from an authorisation or instruction by the competent authorities, would not give rise to a transfer of these goods within the meaning of Article 17 of the VAT Directive.

The VAT Committee also found that for purposes of call-off stock arrangements, “small losses” would mean losses that are below 5% in terms of value or quantity of the total stock (measured as of the date after arrival at the place of storage) if the goods are actually removed or destroyed. However, if it is not possible to determine that date, then the measurement date would be when the goods are found to have been destroyed or missing.

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