ViDA's transfer of own goods scheme offers single registration from July 2028, but opting out brings strict e-invoicing rules by 2030

From 1 July 2028, EU businesses can use a new optional scheme to move stock across borders through a single VAT registration and monthly return instead of multiple registrations. Opting out means facing mandatory structured e-invoicing and real-time reporting from 2030.

The EU’s ViDA package introduces a new Transfer of Own Goods (TOOG) scheme from 1 July 2028, allowing businesses to report all cross-border stock movements through a single VAT registration and monthly return. The scheme is optional, but businesses that decline it will face mandatory structured e-invoicing and real-time transaction reporting from 2030 under the Digital Reporting Requirements.

The current problem: multiple registrations for moving stock

When a business moves its own goods between EU Member States without a sale, EU VAT law treats it as a deemed supply. This legal fiction splits the movement into two legs: an exempt intra-Community supply in the departure state and a taxable acquisition in the arrival state. To account for the acquisition, the business must hold a separate VAT registration in each destination country, even though no actual sale has occurred.

A company with distribution centres in five Member States can end up holding five VAT registrations purely to move its own stock. The call-off stock simplification, introduced in 2020, helps only where goods go to a known customer. For own-warehouse scenarios or stock held for multiple future buyers, the full multi-registration burden remains.

The ViDA solution: single registration from July 2028

Council Directive (EU) 2025/516, adopted on 11 March 2025 and entering force on 14 April 2025, introduces a new Transfer of Own Goods (TOOG) scheme effective 1 July 2028. The scheme sits within ViDA’s second pillar, Single VAT Registration (SVR).

Under TOOG, a business registers in a single Member State of identification (its establishment, or where transport begins for non-EU businesses). It then reports all qualifying intra-EU movements of its own goods on a single, monthly OSS-style return. The intra-Community acquisition in the arrival state is exempt from VAT, and transfers do not appear in the recapitulative statement.

Commission Implementing Regulation (EU) 2026/1869, published on 27 July 2026, supplies the technical detail. The scheme integrates into the existing OSS architecture with a new column G in the identification register and column F in the electronic VAT return message.

Call-off stock is absorbed, not abolished

The TOOG scheme is comprehensive and will absorb the current call-off stock simplification:

No new call-off stock arrangements may begin after 30 June 2028
Existing arrangements may continue under Article 17a until 30 June 2029
From 1 July 2028, all new own-goods movements are reported through TOOG
Any legacy call-off stock still held at 30 June 2029 must be dealt with by that date

In effect, a narrow, condition-heavy simplification for known-customer scenarios gives way to a broad, single-registration scheme covering both known-customer and own-warehouse movements.

The scheme is optional, but opting out has a cost

TOOG is entirely optional. A business may continue to move goods the old way: as a deemed intra-Community supply and acquisition under Articles 17(1) and 21, accounted for through separate VAT registrations in each Member State.

However, opting out is not cost-free. From 1 July 2030, any transfer of own goods not reported through TOOG falls under ViDA’s first pillar: the Digital Reporting Requirements (DRR).

What DRR means for opt-outs

From 2030, businesses that decline TOOG must:

Issue a structured e-invoice in EN 16931 format (not a PDF) within 10 days of the transfer
Generate a self-invoice between their own VAT identities
Report the invoice data to the tax authority in real-time, transaction-by-transaction
Submit data to the Member State issuing the VAT ID, which forwards it to the central VIES database within one day
Abandon the recapitulative statement entirely (it is abolished for DRR-scope transactions)

The practical upshot is stark. The old way preserves local registrations but layers on structured e-invoicing plus real-time reporting for every own-goods movement. For most multi-country operators, TOOG will be more attractive. Businesses with a heavy local footprint (substantial domestic sales or local input VAT) may still find the traditional route, DRR overlay and all, the pragmatic answer.

Intrastat continues regardless

A common misconception is that TOOG relieves businesses of Intrastat obligations. It does not. Intrastat is a statistical regime for collecting data on physical movements of goods between Member States. It is legally and functionally distinct from VAT reporting.

Businesses exceeding national Intrastat thresholds must continue submitting dispatch declarations in the departure state and arrival declarations in the arrival state. They must apply the correct Nature of Transaction code and use a dummy VAT identification number for the partner Member State where no specific customer is known.

Even with a TOOG opt-in, Intrastat remains an enduring, independent workstream that must run in parallel with the OSS return and draw on the same underlying logistics data.

Deductibility and local presence

TOOG makes the cross-border movement itself VAT-neutral at transfer. However, the scheme covers the transfer only. It does not provide a vehicle for recovering local input VAT on unrelated costs (warehousing, handling) or for onward domestic supplies of goods once sold from foreign stock.

A local registration may therefore still be needed for those purposes. Businesses with partial exemption, capital-goods scheme assets, or mixed-use inventory should model these mechanics carefully before opting in. The Implementing Regulation includes provisions for adjusting deduction on transferred goods within the TOOG return.

Court of Justice case law remains the backbone

Decades of CJEU jurisprudence continue to shape the characterization and taxation of own-goods movements, regardless of whether TOOG is adopted.

“The tax authority may not refuse the exemption for the intra-Community transfer solely on that formal ground, where there is no evidence of tax evasion, the goods genuinely moved to another Member State, and the other substantive conditions are met.”
Josef Plöckl v Finanzamt Schrobenhausen, C-24/15

Plöckl established substance over form for own-goods transfers. Collée (C-146/05) reinforced the neutrality principle: an intra-Community supply should not be denied exemption due to formal failures if substantive conditions are met and there is no revenue risk.

EMAG Handel Eder (C-245/04) is the foundational chain-transaction ruling: where goods are subject to a single intra-Community transport involving multiple supplies, the transport can only be ascribed to one supply for exemption purposes. Herst (C-401/18) refined the ascription of transport, focusing on which operator holds the right to dispose of the goods as owner during the single intra-Community transport.

These judgments reinforce that characterization depends on economic substance and the right to dispose, and that formal shortcomings should not nullify substantive VAT treatment in the absence of fraud.

Timeline and next steps

11 March 2025: ViDA adopted (Council Directive (EU) 2025/516)
14 April 2025: ViDA entered into force
1 January 2027: Administrative and registration data changes supporting OSS expansion apply
1 July 2028: TOOG scheme goes live; wider SVR reforms take effect; no new call-off stock arrangements may begin
30 June 2029: Call-off stock simplification ceases entirely
1 July 2030: Digital Reporting Requirements apply for own-goods movements not reported through TOOG

Businesses should now map their intra-EU stock flows, model the TOOG-versus-DRR trade-off, ensure Intrastat compliance, plan for the call-off stock wind-down, and configure ERP and invoicing systems for both the 2028 changes and the 2030 DRR overlay.