Amazon VAT Establishment and Verification Holds
Amazon Sellers Appeal, operated by ASA Compliance Group and led by Or Shamosh, has reinstated 5,600+* Amazon seller accounts and ASINs since 2016.
We handle account suspensions, listing appeals and compliance cases, from the first review through submissions and follow‑ups.
Start with the marketplace, legal entity and exact request in Seller Central. Establishment status, marketplace VAT collection and the documents needed for a review are related questions, but they are not interchangeable.
When marketplace VAT collection can apply
Amazon uses VOEC guidance to explain VAT on e-commerce. Check the transaction before deciding who accounts for VAT: where the goods are held, where they are delivered, the consignment value, the seller’s establishment, customer status and any product exceptions.
| Topic | European Union | United Kingdom |
|---|---|---|
| Low-value imports | IOSS covers qualifying imported consignments with an intrinsic value no greater than €150. It does not cover every product or shipment. | Marketplace collection can apply to qualifying imported consignments of £135 or less. Check customer status and the rules for the destination. |
| Locally held goods | Marketplace deemed-supplier rules can apply to supplies to consumers where goods are already in the EU and the underlying seller is established outside the EU. | Marketplace liability can apply to qualifying sales of goods already in Great Britain by overseas sellers. Business-customer and other conditions matter. |
| Establishment | Review the business and any fixed establishment under the applicable rules. A VAT number alone does not establish a fixed establishment. | Assess the actual business arrangements under UK rules. Treat incorporation records and a mailing address as evidence to review, not a complete answer. |
| Evidence requested | Use the document categories, entity requirements and age limits in Amazon’s notice. Explain registry, VAT, premises and operational records together. | Follow the notice, including any Category A/B document request. Explain Companies House, VAT and operating-address records and any differences. |
| Invoicing | Identify the invoice issuer for the transaction. Retain relevant marketplace tax documents, avoid duplicate VAT charges and check continuing seller obligations. | Check HMRC’s marketplace invoicing rules and Amazon’s transaction documents. Marketplace collection does not remove every seller invoicing or reporting obligation. |
| Regional details | Inventory-country registration and import treatment require separate review. The €150 IOSS threshold is not a general ban on higher-value parcels. | Northern Ireland has specific rules for goods. Identify the shipment route rather than automatically applying the Great Britain rule. |
Read HMRC’s online-marketplace guidance and the European Commission’s OSS and IOSS explanation for the scope of the rules. IOSS and marketplace collection do not replace every domestic VAT obligation.
Establishment is a factual status
Determine the position from how the business actually operates and the applicable VAT rules, with tax advice where needed. Missing a document this week does not change the underlying status. Do not declare the business non-established simply to obtain a faster review.
Where the business is established, explain the basis and provide the evidence requested. Where it is not established, make an accurate declaration and review the VAT treatment of the affected transactions. If records conflict, establish which record is wrong and correct or explain it without inventing an address, employment arrangement or business activity.
Build one establishment evidence file
Use the categories and age limits in the actual Amazon request. Depending on the entity, location and issue, relevant records may include:
- Current registry documents identifying the entity, directors and registered address.
- VAT registration details and the relevant authority’s validation result.
- Evidence of where management and administration take place.
- Premises records, operational invoices and evidence of actual activity at the address.
- Personnel, management or employment records relevant to the claimed establishment.
- Banking records where requested, identifying the account’s relationship to the entity.
- A dated explanation of moves, ownership changes or differences between registered and operating addresses.
A director’s residence, local payroll or a local bank statement may be relevant to a particular request. Do not treat the same combination as a universal legal test for every company. A mailbox or virtual-office document alone may leave the actual operations unexplained.
Prepare a response Amazon can verify
- Identify the request. Record the marketplace, entity, affected payments and deadline. Distinguish an establishment review from identity verification or a different tax issue.
- Reconcile the records. Compare Seller Central with registry and VAT records. Explain legitimate address differences and correct inaccurate information through the appropriate channel.
- Map each document. List which request item each attachment answers. Use complete, readable records meeting the notice’s requirements.
- State the position accurately. Explain the business facts and supporting evidence. Do not copy an establishment declaration that is untrue for the entity.
- Keep the review history. Retain the submission, attachments and replies. Address new requests directly; avoid repeatedly uploading an unchanged packet.
Unexplained mismatches, missing requested evidence, unreadable scans and unsupported declarations can leave a review unresolved. Complete evidence reduces avoidable follow-up but does not guarantee a release date or reactivation.
Check shipping, invoices and historic periods
Ensure ship-from settings reflect the actual route. Give the carrier the required tax and customs data for the applicable scheme, and protect confidential marketplace tax identifiers. Check split consignments, combined orders, returns and higher-value shipments individually. “One order, one parcel” is not a universal tax rule.
Reconcile the tax documents issued for each transaction. Avoid duplicate VAT charging, while checking which invoice and reporting obligations remain with the seller. Have inventory-country registrations and other continuing requirements reviewed.
The UK and EU e-commerce changes began on 1 January 2021 and 1 July 2021 respectively. A historic reconciliation still depends on the entity, transactions, periods and changes in the business. Those start dates alone do not establish an amount owed.
VAT establishment review: common questions
Does a valid VAT number prove establishment?
No. VAT registration and establishment answer different questions. Supply the operational evidence requested and assess the underlying status under the applicable rules.
Must every company have a local director, payroll and bank account?
Do not apply that as a universal checklist. Explain the actual management, people, premises and resources, and provide the particular documents Amazon requests.
Should I change my declaration because a document is missing?
No. Work from the business facts. Identify the missing evidence or ask for clarification of the request rather than selecting a status for speed.
Can I issue an invoice when Amazon collects VAT?
Check the invoice responsibility for that transaction. Retain Amazon’s generated tax documents where applicable, avoid duplicate VAT charges and confirm your remaining invoicing and reporting duties.
When will the hold end?
Read the notice and respond to outstanding requests. Review time and the release decision remain with Amazon; a complete packet does not create a guaranteed deadline.
Amazon references for the applicable marketplace
Establishment review has restricted your account?
Share Amazon’s request, the entities and marketplaces involved, and the evidence already submitted. We can assess the verification case while your tax adviser addresses the applicable VAT position.