# Deemed Supply FAQs
This FAQ answers commonly asked questions about VAT on AWS Marketplace Deemed Supplies in the EU, Norway and UK.
**Topics**
+ **General**
+ [What is a "Deemed Supply" on AWS Marketplace?](#faq-what-is-deemed-supply)
+ [Which transactions can I currently submit through the VAT on Deemed Supply tool?](#faq-which-transactions)
+ **Identifying the Correct AWS EMEA Branch**
+ [How do I identify which AWS EMEA branch I need to invoice?](#faq-identify-branch)
+ [For which countries can I submit a request for VAT on Deemed Supply?](#faq-countries-branches)
+ [What if I sell to Buyers in the UK, Norway and multiple EU countries?](#faq-multiple-countries)
+ **Invoice Submission Process**
+ [How do I submit a VAT invoice for VAT payment?](#faq-how-to-submit)
+ [Can I submit a VAT invoice for a Deemed Supply before the Buyer has paid AWS?](#faq-submit-before-buyer-paid)
+ [Can I consolidate multiple transactions into a single invoice?](#faq-consolidate-invoices)
+ [Is there a time limit for submitting a VAT invoice for a Deemed Supply?](#faq-time-limit)
+ **Mandatory Invoice Fields**
+ [What information must be included on my VAT invoice for a Deemed Supply?](#faq-mandatory-fields)
+ **Invoice Language and Legal References**
+ [What legal reference should I include on my VAT invoice?](#faq-legal-reference)
+ **E-Invoicing**
+ [Do I need to submit an e-invoice instead of a PDF?](#faq-e-invoicing)
+ **VAT Payment**
+ [How and when will I receive the VAT disbursement?](#faq-receive-disbursement)
+ [How can I track the status of my VAT payment?](#faq-track-status)
+ **Refunds and Credit Notes**
+ [What happens if a Buyer requests a refund after I have received the VAT disbursement?](#faq-refund-credit-note)
+ **Self-Billing**
+ [Can AWS generate a VAT invoice for Deemed Supplies on my behalf?](#faq-self-billing)
+ **Reporting and Reconciliation**
+ [How do I identify which transactions I can submit VAT invoices for?](#faq-identify-transactions)
+ [Where can I see whether VAT has been disbursed for my eligible transactions?](#faq-vat-disbursed)
+ **Errors, Duplicates, and Corrections**
+ [What happens if my invoice is rejected?](#faq-invoice-rejected)
+ [Can I submit more than one invoice for the same transaction?](#faq-duplicate-invoice)
+ **Support**
+ [Where can I get additional help with VAT on Deemed Supplies?](#faq-additional-help)
## 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:
+ **Deemed Sale 1:** The Seller is treated as having supplied the Digital Service to the applicable branch of Amazon Web Services EMEA SARL ("AWS EMEA") facilitating the transaction.
+ **Deemed Sale 2:** The branch of AWS EMEA facilitating the transaction is treated as having supplied the Digital Service to the Buyer.
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:
1. The Seller AWS account is located in the UK, Norway or an EU Member State where AWS EMEA SARL has a branch.
1. The Buyer AWS account is located in the same country as the Seller.
1. The AWS Marketplace sale is facilitated by the corresponding AWS EMEA SARL branch in that country.
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).
**Important**
Always use the branch information as displayed in these FAQs. Do not assume the branch name and address based on the Buyer's country alone. The correct legal entity name and address must be verified in the branch listing.
## 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:
Luxembourg (Headquarters)
Legal Name: Amazon Web Services EMEA SARL
Address: 38 Avenue John F. Kennedy, L-1855 Luxembourg
Legal Basis: EU Art 9a / Art 28
Austria
Legal Name: Amazon Web Services EMEA SARL, Austrian Branch
Address: Wiedner Gurtel 13, Turm 24/17.OG, 1100 Vienna, Austria
Legal Basis: EU Art 9a / Art 28
Belgium
Legal Name: Amazon Web Services EMEA SARL, succursale belge
Address: Avenue des Arts 27, 5th Floor, 1040 Brussels, Belgium
Legal Basis: EU Art 9a / Art 28
Czech Republic
Legal Name: Amazon Web Services EMEA SARL, Czech Branch
Address: Sokolovska 689/115, Karlin, 186 00 Prague, Czech Republic
Legal Basis: EU Art 9a / Art 28
Denmark
Legal Name: Amazon Web Services, Dansk filial af Amazon Web Services EMEA SARL, Luxembourg
Address: c/o Spaces Ny Carlsberg Vej 80, 1799 Copenhagen, Denmark
Legal Basis: EU Art 9a / Art 28
Estonia
Legal Name: Amazon Web Services EMEA SARL, Eesti filiaal
Address: Sopruse pst 145, Kristiine linnaosa, Tallinn, Harju maakond 13425, Estonia
Legal Basis: EU Art 9a / Art 28
Finland
Legal Name: Amazon Web Services EMEA SARL, sivuliike Suomessa
Address: c/o HEM13 Mikonkatu 7, 00100 Helsinki, Finland
Legal Basis: EU Art 9a / Art 28
France
Legal Name: Amazon Web Services EMEA SARL, succursale francaise
Address: 31 place des Corolles, Tour Carpe Diem, 92400 Courbevoie, France
Legal Basis: EU Art 9a / Art 28
Germany
Legal Name: Amazon Web Services EMEA SARL, Niederlassung Deutschland
Address: Anni-Albers-Str. 21, 80807 Munchen, Deutschland
Legal Basis: EU Art 9a / Art 28
Greece
Legal Name: Amazon Web Services EMEA SARL Greek Branch
Address: Athens Green Plaza, Ag. Konstantinou 59-61, Suite 136, Maroussi, Athens, Greece
Legal Basis: EU Art 9a / Art 28
Ireland
Legal Name: Amazon Web Services EMEA SARL, Irish Branch
Address: One Burlington Plaza, Burlington Road, Dublin 4, Ireland
Legal Basis: EU Art 9a / Art 28
Italy
Legal Name: Amazon Web Services EMEA SARL, sede secondaria
Address: Viale Monte Grappa 3/5, 20124 Milan, Italy
Legal Basis: EU Art 9a / Art 28
Netherlands
Legal Name: Amazon Web Services EMEA SARL, Dutch Branch
Address: Mr. Treublaan 7, 1097 DP Amsterdam, Netherlands
Legal Basis: EU Art 9a / Art 28
Poland
Legal Name: Amazon Web Services EMEA SARL spolka z ograniczona odpowiedzialnoscia Oddzial w Polsce
Address: Generation Park Z, 9th floor, ul. Towarowa 28, Warsaw, Poland
Legal Basis: EU Art 9a / Art 28
Portugal
Legal Name: Amazon Web Services EMEA SARL, Sucursal em Portugal
Address: Avenida D. Joao II, 50, andar 4, Edificio Mar Vermelho, Parque das Nacoes, 1990-095 Lisboa, Portugal
Legal Basis: EU Art 9a / Art 28
Romania
Legal Name: Amazon Web Services EMEA SARL Luxemburg Sucursala Bucuresti
Address: District 2, 4B si 2-4 George Constantinescu Street, Lot 1, Building A (Section A), Floor 11, Bucharest, Romania
Legal Basis: EU Art 9a / Art 28
Spain
Legal Name: Amazon Web Services EMEA SARL, sucursal en Espana
Address: Calle de Ramirez de Prado 5, 28045 Madrid, Spain
Legal Basis: EU Art 9a / Art 28
Sweden
Legal Name: Amazon Web Services EMEA SARL, Sverige filial
Address: Malmskillnadsgatan 36, Stockholm, Sweden
Legal Basis: EU Art 9a / Art 28
Norway
Legal Name: Amazon Web Services EMEA SARL, Norwegian Branch
Address: c/o Aker Brygge Business Village, 4th Floor, Grundingen 6, 0250 Oslo, Norway
Legal Basis: NO VAT Act §§ 3-1
United Kingdom
Legal Name: Amazon Web Services EMEA SARL, UK Branch
Address: 1 Principal Place, Worship Street, London, EC2A 2FA, United Kingdom
Legal Basis: UK VAT Act 1994, s.47(4)
## 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:
1. Select Deemed Supply-eligible line items to upload a VAT invoice.
1. Click Apply VAT disbursement once line items are selected.
1. Review the submission page details and upload the VAT invoice by clicking the Upload file button.
1. Once you have reviewed the submission details, click the Submit disbursement button and confirm.
## 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:
1. AWS systems have validated the VAT invoice you submitted for the transaction.
1. AWS has received payment from the Buyer.
## 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:
+ All transactions on the consolidated invoice must relate to the same AWS EMEA branch (i.e., same country).
+ The VAT amounts on the consolidated invoice must match the sum of the deemed supply VAT amounts for the underlying transactions.
+ The invoices which are consolidated must be in the same original offer currency.
## 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.
1. **AWS EMEA Branch Bill-To Address** — The registered address of the AWS EMEA SARL branch to which the invoice is addressed.
1. **AWS EMEA Branch VAT Number** — The local VAT identification number of the AWS EMEA SARL branch.
1. **Type of Document** — Specify whether the document is an Invoice or a Credit Note.
1. **Supplier Name** — Your legal entity name as registered with your local tax authority.
1. **Supplier Address** — Your legal registered address.
1. **Supplier VAT ID** — Your local VAT identification number.
1. **Invoice Date** — The date on which the invoice is issued.
1. **Invoice Number** — Your unique sequential invoice number (1-50 characters).
1. **Invoice Currency** — Must match the offer currency or local currency.
1. **VAT Legal Currency** — The currency in which VAT must be displayed.
1. **Invoice Description** — Description of the supply including quantity and unit price.
1. **Net Amount** — Total net amount (excluding VAT).
1. **VAT Rate (%)** — The applicable domestic VAT rate.
1. **VAT Amount in Invoice Currency** — Net Amount multiplied by VAT rate.
1. **VAT Amount in Legal Currency** — Total VAT in legal currency.
1. **Invoice Total** — Net Amount plus VAT Amount.
## 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.
**Important**
AWS will only disburse the VAT amount stated on the invoice. The net amount of the deemed supply is already included in your standard Marketplace disbursement cycle. AWS recommends that your invoice includes the disclaimer "VAT only due for payment".
## 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:
+ **PENDING:** Invoice was received.
+ **ACCEPTED:** Invoice received and validated, awaiting payment from the Buyer.
+ **REJECTED:** Invoice failed validation. Check the rejection reason and re-upload a corrected invoice.
## 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:
+ Legal VAT amount (in local currency and USD)
+ Legal currency
+ Seller's local VAT ID
+ Buyer's legal address
+ Buyer billing country
+ AWS EMEA branch that facilitated the transaction (including branch name, address, and VAT ID)
+ Seller billing country
+ VAT amount calculated using the applicable FX rate (for consolidated billing)
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:
+ **Seller Reports:** The Seller reports include new data points indicating whether VAT payment on Deemed Supplies is applicable and whether it has been disbursed for each transaction. A new "Seller Invoice ID" column and "VAT on Deemed Supplies Flag" column have been added.
+ **Disbursement Dashboard:** The Collection and Disbursement dashboard displays the Seller Invoice ID and VAT on Deemed Supplies Flag for all transactions involving VAT payment, allowing you to reconcile disbursements with your uploaded invoices.
+ **Seller Data Delivery Service (SDDS):** The data feeds have been updated to include VAT disbursement data for programmatic access.
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:
+ Invoice format non-compliant (e.g., missing mandatory fields).
+ VAT amount on invoice does not match the calculated VAT for the transaction(s).
+ Incorrect AWS EMEA branch name or VAT number.
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.