Deemed Supply FAQs

This FAQ answers commonly asked questions about VAT on AWS Marketplace Deemed Supplies in the EU, Norway and UK.

What is a "Deemed Supply" on AWS Marketplace?

Under EU, Norway and UK VAT rules, when AWS Marketplace facilitates the sale of Digital Services (e.g. SaaS, AMI), the law establishes two back-to-back supplies for VAT purposes only:

This treatment arises under the provisions of Article 9a of EU VAT Council Regulation 282/2011 of 15 March 2011 and Article 28 of EU VAT Directive 2006/112/EC (for EU transactions), the provisions of Section 47(4) of the UK VAT Act 1994 (for UK transactions) and the Merverdiavgiftsloven - Norwegian VAT Act § 3-1, second paragraph (for Norway transactions). These are collectively referred to as "Marketplace Operator Rules".

Please note that this treatment is for VAT purposes only and it does not change the commercial and legal relationship between Buyer and Seller.

As a result of the Deemed Supply provisions, when both the Seller and the Buyer are in the same EU Member State, Norway or in the UK, and the transaction is facilitated by the relevant AWS EMEA branch in the same country, an obligation might exist for VAT to be paid by the Marketplace Operator to the Seller. Sellers can issue a VAT invoice to that AWS EMEA branch facilitating the transaction and AWS EMEA will pay the VAT stated on the invoice, subject to receipt of a valid VAT invoice.

Which transactions can I currently submit through the VAT on Deemed Supply tool?

Currently, you can submit invoices for transactions of AWS Marketplace sales of Digital Services where all three of the following conditions are met:

This applies to all Marketplace Private Offer (MPPO) transactions, including both B2B and B2C sales. Consulting Partner Private Offer (CPPO) transactions between ISV - Distributor and ISV/Distributor - Channel Partners are currently out of scope for the VAT payment on Deemed Supply automation. Channel Partners can submit VAT invoices for their Private Offer transactions under a CPPO agreement.

For any other transactions where the Seller needs to raise an invoice under Marketplace Operator rules (i.e. cross-border sales), please continue to email invoices (PDF) to: awsmpeuisv@amazon.com.

How do I identify which AWS EMEA branch I need to invoice?

Your invoice must be addressed to the AWS EMEA branch where the Buyer is located. The Buyer's country code determines the correct branch. To identify the country of the branch facilitating the transaction, navigate to the Tax Information Tab in the AWS Marketplace Management Portal (AMMP).

For which countries can I submit a request for VAT on Deemed Supply?

The following countries and branch names are where Sellers can submit for VAT payment under Deemed Supply rules on AWS Marketplace:

What if I sell to Buyers in the UK, Norway and multiple EU countries?

If you sell to Buyers with AWS accounts in multiple countries from multiple Seller accounts, you must issue separate invoices to each relevant AWS EMEA branch facilitating the transaction. Each branch has its own name, address, and VAT identification number.

How do I submit a VAT invoice for VAT payment?

You can submit a VAT invoice through the AMMP Portal. Navigate to the Tax Information tab in the AWS Marketplace Management Portal. Then:

Can I submit a VAT invoice for a Deemed Supply before the Buyer has paid AWS?

Yes. You can upload your VAT invoice as soon as the transaction has been reported, even if AWS has not yet received payment from the Buyer. AWS Marketplace will hold the invoice and process the VAT disbursement once both conditions are met:

Can I consolidate multiple transactions into a single invoice?

Yes. You may consolidate all AWS Marketplace deemed supply transactions for a given AWS EMEA branch into a single VAT invoice, provided the following conditions are met:

Is there a time limit for submitting a VAT invoice for a Deemed Supply?

You should submit your VAT invoice as soon as practicable following the transaction. VAT invoices for Deemed Supplies that are more than 12 months old may be rejected depending on the country. AWS strongly recommends submitting invoices within the same VAT reporting period in which the deemed supply occurred, or as soon as possible thereafter.

What information must be included on my VAT invoice for a Deemed Supply?

Your VAT invoice must contain all the fields listed below. Invoices that do not contain all mandatory fields will be rejected.

What legal reference should I include on my VAT invoice?

AWS recommends including a reference to the applicable Marketplace Operator Rules in the invoice description field.

For EU transactions, include: "Supply of Digital Services deemed to be made under the provisions of Article 9a of EU VAT Council Implementing Regulation (EU) No 282/2011 of 15 March 2011 and Article 28 of EU VAT Directive 2006/112/EC. VAT only due for payment."

For UK transactions, include: "Supply of Digital Services deemed to be made under the provisions of Section 47(4) of the UK Value Added Tax Act 1994. VAT only due for payment."

For Norway transactions, include: "Supply of Digital Services deemed to be made under the provisions of Merverdiavgiftsloven (Norwegian VAT Act) § 3-1, second paragraph, whereby the marketplace operator is treated as having received and supplied the service. VAT only due for payment."

This language may be included in the Invoice Description field or as a separate line item or footnote on the invoice.

Do I need to submit an e-invoice instead of a PDF?

In jurisdictions where e-invoicing is mandatory (e.g., Italy via the Sistema di Intercambio), you must submit your e-invoice in the required electronic format. XMLs must be submitted for Italy, Belgium, Poland and Romania transactions. Please note that XMLs will be rejected if used for VAT payment requests in any other jurisdiction.

Where e-invoices are represented by a PDF, you can submit e-invoices through the AMMP portal. AWS Marketplace will validate your e-invoice against the applicable government system requirements. If validation fails, you will receive an error response detailing the issue, and you will be asked to re-submit a corrected e-invoice.

For jurisdictions where e-invoicing is not currently mandatory, you must submit your invoice in PDF format. As more EU Member States adopt mandatory e-invoicing requirements, additional e-invoicing formats may be required. AWS will communicate any changes to supported formats in advance.

How and when will I receive the VAT disbursement?

Once your VAT invoice has been validated and the Buyer has paid the corresponding invoice to AWS, the VAT amount will be disbursed to you automatically. The VAT disbursement is separate from your standard Marketplace disbursement.

How can I track the status of my VAT payment?

You can track the status of all your VAT invoices in the Tax Information tab of the AMMP portal. Each invoice will display one of the following statuses:

What happens if a Buyer requests a refund after I have received the VAT disbursement?

If a Buyer is issued a refund for a transaction on which you have already received a VAT disbursement, you will be required to return the VAT amount to AWS. You must issue a credit note to the corresponding AWS EMEA branch. The credit note must reference the original invoice number and follow the same format as the original VAT invoice, with the Type of Document field set to "Credit Note".

To submit a Credit Note, please Contact Us through the AMMP portal.

Can AWS generate a VAT invoice for Deemed Supplies on my behalf?

No. At the moment AWS Marketplace does not offer a Self-Billing option where AWS generates the VAT invoice on your behalf for deemed sale transactions.

How do I identify which transactions I can submit VAT invoices for?

The Tax Dashboard in the AMMP portal has been enhanced to include data columns to help you identify deemed sale transactions and self-serve the generation of your VAT invoice, including:

You can apply filters on these columns to retrieve the exact transactions where you can submit a VAT invoice for payment. The Tax Dashboard has a 1 to 2 day delay for the latest data to be reflected.

Where can I see whether VAT has been disbursed for my eligible transactions?

VAT disbursement on Deemed Supplies information is available in the following locations:

These reports are designed to support your internal reconciliation, financial reporting, and audit requirements.

What happens if my invoice is rejected?

If your invoice fails validation, you will receive an error response identifying the specific issue. Common rejection reasons include:

You can correct the issue and re-upload the invoice through the AMMP portal.

Can I submit more than one invoice for the same transaction?

No. The automated validation system includes controls to prevent duplicate invoicing.

Where can I get additional help with VAT on Deemed Supplies?

For questions about the VAT on Deemed Supplies invoicing process, invoice submission, or disbursement status, please Contact Us through the AMMP portal.

For tax-specific questions regarding the Deemed Supply treatment, applicable VAT rates, or legal references, please consult your tax advisor. AWS is unable to provide tax advice on the VAT treatment of your individual transactions.