Luxembourg Submits First-Stage ViDA VAT Bill Covering Platforms, OSS and Call-Off Stock

Summary

Luxembourg has submitted draft Bill No. 8812 to implement the first stage of Council Directive (EU) 2025/516. The Bill addresses deemed suppliers, call-off stock, the EUR 10,000 B2C threshold, OSS rules, selected energy supplies and interaction between OSS and the small-enterprise exemption.
The call-off stock regime would close to new transfers after 30 June 2028 and cease applying from 1 July 2029. The proposal reflects the planned introduction, from 1 July 2028, of an expanded OSS mechanism for cross-border transfers of a business’s own goods.
Platforms, non-EU service providers, energy suppliers, multi-country retailers and businesses using the EU small-enterprise exemption should review the proposal. The Bill was submitted on 30 July 2026 and remains subject to Luxembourg’s parliamentary process, including possible amendments before adoption.

Article

The Luxembourg government has submitted draft Bill No. 8812 to Parliament as the first stage of domestic implementation of the EU VAT in the Digital Age reforms introduced by Council Directive (EU) 2025/516. The Bill was submitted on 30 July 2026 and is not yet enacted.

Under the proposal, Luxembourg’s deemed-supplier rule for electronic interfaces would be broadened. A platform facilitating supplies of goods within the EU by a non-EU-established seller could be treated as buying and reselling those goods not only when the customer is a private consumer, but also when the customer is a taxable person or non-taxable legal entity whose intra-Community acquisitions are not subject to VAT.

The Bill would also phase out the call-off stock simplification. No new qualifying transfers could be made after 30 June 2028, although the existing conditions, including the 12-month period for transfer to the intended purchaser, would continue to operate for eligible movements made by that date. The relevant provisions would cease to apply from 1 July 2029. Businesses using Luxembourg warehouses should reconcile inventory and assess whether outstanding stock can complete the existing regime within the transitional period.

For the EUR 10,000 B2C threshold, the proposal clarifies that only intra-Community distance sales dispatched from the supplier’s Member State of establishment count toward the threshold. Sales dispatched from inventory in another Member State would not be included.

The non-EU OSS would be extended to all services supplied within the European Union by non-EU-established taxable persons to non-taxable recipients. The Bill also clarifies the chargeable-event rules for transactions reported through the EU and non-EU OSS arrangements.

Special transitional treatment is proposed for supplies of gas, electricity, heating and cooling to specified customers. Between 1 January 2027 and 30 June 2028, those supplies would be treated as intra-Community distance sales so that they can be declared through the EU OSS. From 1 July 2028, they would fall within the expanded normal EU scheme.

The Bill additionally clarifies that a business applying the small-enterprise exemption cannot simultaneously use OSS. It would have to revoke the exemption before entering an OSS scheme. A proposed 35-working-day period would govern when the small-enterprise exemption takes effect in another Member State.

A separate Luxembourg bill released on 30 July 2026 concerns mandatory domestic B2B e-invoicing. Public reporting identifies that measure as a distinct proposal with implementation beginning in 2028, so it should not be conflated with Bill No. 8812. [kpmg.com], [kpmg.com]

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Luxembourg publishes draft law implementing ViDA measures applicable from 1 January 2027

Luxembourg has submitted Draft Law No. 8812 to implement the initial phase of the EU’s VAT in the Digital Age (ViDA) measures, effective from January 1, 2027.
This draft law primarily focuses on expanding and clarifying the One-Stop-Shop (OSS) scheme, adjusting VAT chargeability for these transactions, phasing out the call-off stock simplification regime, and making targeted changes to Import One-Stop Shop (IOSS), deemed supplier rules, and the exemption for cross-border small and medium-sized enterprises.
The draft law is the first step in a phased implementation, with other ViDA reforms, such as EU-wide digital reporting and enhanced e-invoicing obligations, to be addressed in future legislation.

Source EY