Value Added Tax Consolidation Act 2010 section 23A

Call-off stock arrangements

Section 23A provides simplified VAT treatment for call-off stock arrangements, where a non-established supplier moves goods into Ireland for later supply to a pre-identified Irish VAT-registered customer.

• A transfer of goods under qualifying call-off stock arrangements is not treated as a supply of goods for consideration, removing the need for the foreign supplier to register for Irish VAT solely because of the stock movement.
• When ownership passes to the Irish customer within 12 months, the transaction is treated as an intra-Community supply by the foreign supplier and an intra-Community acquisition by the Irish customer.
• If the goods are not supplied within 12 months and none of the failsafe events apply, a deemed supply arises the day after the 12-month period expires; however, goods returned to the dispatch country within that period do not trigger a supply.
• The original Irish customer may be substituted by another qualifying customer within the 12-month window without triggering a supply, provided all conditions remain met and the substitution is recorded in the supplier's register.