Amazon Has Already Filed Two Years of Your EU Sales Data With Tax Authorities

The first report went to EU tax authorities in January 2024. The second followed in January 2025. If you have been selling through Amazon on any EU marketplace and your VAT filings do not align with what Amazon submitted, tax authorities across every EU member state now have the data to identify that discrepancy.

The short answer: under the EU's DAC7 directive, digital platforms including Amazon are legally required to report seller data to tax authorities annually. Amazon collects your quarterly sales figures, fees, and tax identification information throughout the year, then submits the full picture by 31 January each year. That data is then automatically exchanged between all EU member states - so a gap between what Amazon has reported and what you have filed is no longer a theoretical compliance risk. It is a visible one.

For most brands that have entered or are scaling in Europe, this changes the compliance risk calculation significantly. The question is no longer whether a gap might eventually surface. It is whether tax authorities have yet looked at it.

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What Amazon Reports Under DAC7 - and Who Receives It

DAC7 places the reporting obligation on the platform, not the seller. Amazon collects and submits your full legal name and primary address, your EU member state of residence, your tax identification number, your VAT registration numbers, the total consideration paid or credited to you broken down per quarter, and any fees, commissions, or taxes the platform has withheld.

That data goes to the tax authority in the EU member state where Amazon's reporting entity is registered. From there, it is automatically exchanged to every other EU member state. A German tax authority receives the same data as a French or Dutch one. The sharing is not discretionary - it is built into the directive by design.

The UK operates its own equivalent under HMRC's Model Rules for Reporting by Platform Operators, effective from January 2024. Amazon reports UK seller data to HMRC on the same annual cycle. We covered the UK angle in detail in our post on HMRC and overseas seller reporting - but for brands selling across both the UK and EU, both reporting regimes now apply simultaneously.

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Why the Quarterly Breakdown Matters

The DAC7 report is filed annually, but the data Amazon submits shows activity per quarter. Tax authorities are not looking at a single annual lump figure. They are looking at sales volumes by quarter, which they can compare directly against the quarterly VAT returns you filed for the same periods.

If your Amazon sales in Q3 2023 show turnover that was not captured in your VAT filing for that quarter, that inconsistency is visible. The same logic applies to every quarter since January 2023.

Two rounds of reports have already been filed. A third covering the 2025 calendar year will go to tax authorities by 31 January 2026. Every year the picture becomes more complete - and the historical data that has already been submitted does not disappear.

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The Gap Between "Having a VAT Partner" and Being Compliant

The most common response we hear when EU compliance comes up with incoming clients is: "We have a VAT partner in place."

Having a VAT partner appointed and knowing whether your filings are correct are two different things. A partner files what they are given. If the data being extracted from Amazon is incomplete, if quarterly figures are being reconciled incorrectly, or if the VAT structure was set up in 2022 and never reviewed against subsequent rule changes, filings can run on time and still be wrong.

Most of our EU engagements begin not with setting something up, but with understanding what is already in place. That means reviewing the brand's current compliance profile - which registrations exist, in which countries, under which entity, and whether the VAT numbers registered with Amazon match the ones being used to file returns. Only once that picture is clear do we work with recognised VAT compliance providers in the relevant markets to build or correct the process going forward.

That ongoing management is the part most brands have not had. We make sure the right data is extracted from Amazon settlement reports each quarter, that figures are checked before they are submitted, and that the returns align with what Amazon has reported to the authorities. If a question ever comes from a tax authority, we need to be able to demonstrate that the numbers were verified and submitted correctly - not simply that a provider was in place.

The pattern we see repeatedly is brands who believe their compliance is handled - because something has been filed, because a provider is in place - but who cannot confirm whether the figures Amazon submitted to the German, French, or Dutch tax authority match their VAT returns for the same periods. In most cases, when we look, something is missing.

A US electronics brand that came to us after a failed EU expansion had spent approximately £100,000 before we were involved. The VAT structure had been incorrect from the outset. The filing entity was wrong, the figures being reported to the German tax authority were inconsistent with the actual trading activity, and Amazon had suspended the account. Rebuilding the compliance structure from the ground up - including correcting the historical VAT position - resulted in a five-figure VAT rebate and the account being reinstated and trading within six weeks. Under DAC7, that kind of structural error is no longer something that might surface at a future audit. The underlying data is already with the relevant tax authority. It is there to look at.

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What to Check Before the Next Report Is Filed

The January 2026 submission covers 2025 calendar year data. Before that report lands, four things are worth confirming.

First, is your VAT number correctly registered in every EU country where you hold FBA inventory? Amazon Pan-EU places stock across multiple countries. Each country where inventory is stored creates a VAT obligation - not just the countries where sales are made.

Second, are your EPR registrations current? Extended Producer Responsibility requirements covering packaging, batteries, and electrical goods have been updated multiple times since 2022. A registration correct at launch may not reflect what is required today.

Third, has anyone cross-referenced your quarterly Amazon settlement data against your actual VAT filings for the same periods? This is the alignment check that most brands have never done. DAC7 means tax authorities now have the Amazon side of that comparison already.

Fourth, was your EU VAT structure set up before January 2023? If so, it predates the first DAC7 reporting period. It is worth reviewing whether the structure that was put in place still reflects how you are actually trading - and whether what has been filed aligns with what Amazon has now submitted twice.

If the honest answer to any of those questions is "we are not certain," that uncertainty is worth resolving before the next report goes in.

If you have not reviewed your EU compliance profile since 2023, or if you received an Amazon TIN validation request and are not certain your VAT filings align with what was submitted, we are happy to take a look at what is in place. Most of those conversations start with a straightforward review of your current profile - which registrations exist, in which countries, and whether the numbers match. Talk to us here.

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Frequently Asked Questions

What is DAC7 and does it apply to all Amazon sellers?

DAC7 is an EU directive requiring digital platforms including Amazon to report seller data to tax authorities annually. It applies to sellers who are resident in an EU member state, or who sell goods to EU consumers through the platform. A de minimis exclusion exists, but it requires a seller to stay under both conditions simultaneously - fewer than 30 transactions AND total consideration below €2,000 in the reporting period. Crossing either limit alone is enough to trigger reporting: five transactions worth €3,000 puts you in scope, and so do 40 transactions worth €500. Any established brand running meaningful EU sales volume is well within scope.

What data does Amazon submit to tax authorities under DAC7?

Amazon submits your legal name, address, tax identification number, VAT registration number, and the total consideration paid or credited to you each quarter, along with any fees or taxes withheld. The data covers each calendar year and is submitted by 31 January of the following year. It is then automatically shared with tax authorities across all EU member states, including countries where you may not have filed returns.

It is worth noting that Amazon has been actively enforcing TIN collection from sellers as part of its own DAC7 obligations. Sellers who did not provide a valid Tax Identification Number received requests to update their account information - and in some cases faced account restrictions until the information was supplied. If you received one of those requests and updated your TIN, that information is now included in what Amazon has already filed.

Does the UK equivalent apply separately from EU DAC7?

Yes. The UK implemented its own version - the Model Rules for Reporting by Platform Operators - effective from January 2024. Amazon reports UK seller data to HMRC on the same annual cycle, covering UK marketplace sales independently of EU reporting. Brands selling on both Amazon UK and Amazon EU are subject to both reporting regimes.

If I have a VAT compliance partner in place, am I covered?

Having a VAT partner means filings are being submitted. It does not confirm those filings align with the data Amazon has reported for the same periods. The question is whether someone is actively cross-referencing your quarterly Amazon settlement data against what has been filed - and whether the VAT structure reflects how you are actually trading today. If you cannot answer both questions confidently, the position is worth reviewing.