How is an amazon fba sellers business taxed across borders?

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Answer

Fulfilment inventory stored in another country is physical presence, which can create both an indirect-tax registration obligation and a permanent-establishment question for the seller's own company. The first foreign obligation in this sector is rarely income tax, which is why it is discovered late.

The rule for this sector

Fulfilment inventory stored in another country is physical presence, which can create both an indirect-tax registration obligation and a permanent-establishment question for the seller's own company.

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The exception

My stock is in warehouses in countries I have never visited.

How is an amazon fba sellers business taxed across borders?
ItemAmount
Total salesC$751,000
Markets sold into5
Sales in the largest marketC$307,910
Assumed registration test thereC$45,000
Registration required in that market?Yes

One market crosses its own test, so registration and collection start there on the trigger date — and the other 4 markets are tested separately, on their own rules. Registering in one does nothing for the next.

The figures here are an illustration, not an engagement: amounts are picked so the mechanism is easy to follow, and every rate or threshold is an assumption of the example. Before anything is filed for you, each one is confirmed with the issuing authority for your own tax year.

Your next step

The full treatment — who it binds, the deadline, the penalty and the fixed fee — is on Cross-border tax for amazon fba sellers. We will tell you if you do not need us. That happens more often than you would expect.

Checked and signed off for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.

International tax planning for technology businesses — what this page covers

Most readers of this page are looking for international tax planning for technology businesses. What follows sets out how it works for amazon FBA sellers: who is caught by it, what has to be filed, and what the work costs, agreed before it begins.

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Case study 1

Finding out which countries a seller's stock was actually in

The client knew where they sold and had never asked where their goods were. The platform's inventory placement data answered it, and the list was longer than expected, including countries they had no idea they were trading in. The work was to date the first storage in each country, test the local registration trigger against that date rather than against sales alone, and open the registrations already due. The engagement produced a country-by-country record of where stock had been held, and registrations back-dated to the correct dates rather than to the day we started.

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Case study 2

Testing whether a fulfilment centre made the company taxable there

Stock had been held in one country for years and the seller's activity there had grown well past simple storage. That is the point at which the treaty question stops being theoretical. The work was to describe what actually happened at and around the site, who instructed it, and whose staff carried it out, then test that description against the treaty between that country and the company's home country rather than against a general impression. The engagement produced a written analysis, a position the company could defend, and the filings that position required locally.

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Case study 3

Tying platform reports to the returns the company had to file

The company's own accounts, the platform's reports and the indirect-tax returns had never agreed, and nobody could say which of them was right. The work was structural: separating sales the platform accounted for from sales the company accounted for, identifying movements of stock between countries that are reportable in their own right, and rebuilding each period from transaction data rather than from summaries. The engagement produced restated returns for the open periods and a reconciliation the company now runs before each filing instead of after a query.

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Case study 4

Narrowing storage settings and closing the registrations that followed

The seller decided the extra reach was not worth the compliance load in several markets and restricted cross-border storage. Changing the setting is the easy part. The work was the sequence afterwards: letting existing stock sell through, keeping the registrations alive for as long as any obligation remained, filing the final returns, and then closing each account properly rather than abandoning it. The engagement produced clean deregistrations in each market, final filings on record, and platform settings that match the registrations the company still holds.

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Case study 5

A home country return for a company selling almost entirely abroad

The company was incorporated at home, run from there, and sold almost entirely to customers elsewhere, which its earlier returns had presented as though the activity abroad did not exist. Residence had not moved, so the whole profit remained reportable at home. What needed working out was how much of it was also taxable abroad, and what relief the home return should give for that. The engagement produced a home return reporting everything, a claim for relief supported by the foreign filings, and a note explaining the basis of the attribution.

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Case study 6

Entering a new market with the registration in place first

The client wanted to open a new market and, unusually, asked before the first pallet moved. We established the local trigger, the registration lead time, and what the platform would do with the stock once it arrived there. Registration was applied for so that it existed before goods were stored, pricing was set to carry the tax from the first order, and the platform settings were aligned with both. The engagement produced a market entry with no period of unregistered storage and no historic exposure to disclose afterwards.

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Case study 7

A US LLC Owned by a Canadian, Taxed Twice by Design

The two countries classify an LLC differently, so the credit relief that ought to apply frequently does not. The engagement looks at whether the structure can be changed, and where it cannot, at how to make the credit work.

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Case study 8

A US Citizen Settled in India, Filing on Both Sides

Residence in India and citizenship in the United States produce two annual returns for one income. The order decides the credit, and the Indian financial year and the US calendar year have to be reconciled before either is prepared.

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The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

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Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

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A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

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Questions that come up on Amazon FBA sellers

Does Amazon moving my stock abroad create a tax problem?

It can, and it is the part of the arrangement a seller has least visibility over. Fulfilment inventory held in another country is physical presence, whatever your intention was in sending it there, and the platform decides where it sits. Presence of that kind can create an indirect-tax registration obligation in that country, and it raises a separate and harder question about whether your own company has become taxable there on its profits. Neither question waits for you to notice it. The first practical step is to obtain the platform's inventory placement data and find out which countries you are actually trading from.

Does inventory in a foreign warehouse create a permanent establishment?

It is a real question rather than a formality, and the answer is not automatic. Treaties distinguish activity that is preparatory or auxiliary from activity that amounts to carrying on the business in that country, and holding a stock of goods for delivery has historically sat on the permissive side of that line. What has changed is how much of a modern fulfilment operation happens at the warehouse, and who controls it. So the analysis is about what is done at the site and on whose behalf, not simply about whether goods are present. It has to be worked country by country, against the treaty that country has with yours.

Why do Amazon's reports not match the returns I must file?

Because the reports describe a marketplace's obligations and your return describes yours, and those are not the same set. The platform accounts for tax on the transactions it is required to, in the jurisdictions imposing that requirement. It does not account for movements of your own stock between countries, which can be reportable events in their own right, and it does not cover sales made through any other channel. Your return has to show the sales the platform handled, the sales you handled, and the stock movements, each under its own treatment. Reconciling the platform data to that is a recurring job, not a one-off correction.

I incorporated at home and sell abroad, where do I pay tax?

Your company pays tax on its profits where it is resident, which is normally where it was incorporated and is managed. That is not the end of the matter. Where it has enough presence in another country, that country can tax the profits attributable to what happens there, and the treaty decides how the two claims sit together so the same profit is not taxed twice. Stock held in a foreign fulfilment centre is exactly the fact pattern that puts this question on the table. Selling almost entirely abroad does not by itself move the company's residence, and it does not remove the home filing obligation.

Do I need a registration in a country I have never visited?

Whether you have been there is not one of the tests. The obligation follows the goods and the sales, not the seller's travel. If your stock is stored in a country, the presence is the stock, and the registration question is asked of the person who owns it, which is you. This is the part clients find hardest to accept, because a warehouse they have never seen, chosen by a platform, in a country where they have no business relationship, has created an obligation in their own name. Get the inventory placement report, list the countries it names, and take them one at a time.

Can I stop Amazon storing my stock in other countries?

Usually to a degree, through the programme settings you agreed to when you enrolled. Restricting cross-border placement limits where the platform may hold your goods, which limits where obligations arise, and it also limits delivery speed and reach in those markets. That is a commercial decision with a compliance consequence and it should be taken as one, rather than left at whatever the default happens to be. Whichever way you go, the setting has to match the registrations you actually hold. Sellers get into difficulty when the settings are changed inside the platform and nobody tells the person preparing the returns.

Do I pay Canadian tax if I live abroad?

Only if you remain a Canadian tax resident. Residency follows your ties rather than your address, so leaving while your home and family stay usually does not end it. Non-residents remain taxable on Canadian-source income — employment or business income earned in Canada, dispositions of taxable Canadian property, and passive amounts subject to withholding. The year you leave is its own exercise, with a deemed disposition and its own schedules. See leaving Canada.

How many days can I spend in a country before I become tax resident?

It depends on the country, and a day count is only ever the start. Many use a threshold in a tax year, some also look at averages across several years, and some have no day test at all and decide on where your home and life are. Two countries can both conclude you are resident, which is what the treaty tie-breaker exists to settle. Counting days without checking the tie-breaker is how people end up filing as resident nowhere. See the residency tie-breaker.

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