Two Maps That Don't Match

Amazon will happily let you store inventory in six countries before anyone tells you three of them just gave you a permanent establishment. FBA's warehouse map and your tax-exposure map are not the same map, and most sellers only compare the two after the first notice arrives from a tax authority they didn't know they owed anything to.

The good news is that most of this is mappable in advance. The bad news is that the US side of it, long treated as a simple "$100K or 200 transactions" rule of thumb, no longer has a simple rule of thumb to reach for.

What's Actually Stacked on Top of You

Run a global e-commerce business and you're carrying, simultaneously: a corporate entity somewhere, your own personal tax residency somewhere else, physical inventory sitting in whatever countries your FBA warehouses land in, customers everywhere, sales tax and VAT/GST obligations in each of those customer countries, corporate tax where the entity sits, personal tax where you sit, and permanent-establishment questions raised by the warehouses themselves. None of these layers move together, which is exactly why treating them as one problem produces bad answers.

The Four Layers, Separately

Your corporate entity (a Panama SA, a Delaware or Wyoming LLC, a UK Ltd, an Estonian OÜ, a UAE free zone company, a Cyprus Ltd, among others) should be chosen against your personal residency, your primary market and the substance requirements each option carries, not against which one sounds most tax-efficient in isolation.

Your personal residency drives most of the total tax outcome regardless of what the entity looks like — this is the layer worth spending the most time on, and it's covered in full in our residency framework for online business owners.

Sales tax, VAT and GST compliance follows your customers, not your entity: EU sales need EU VAT registration (or the Non-Union OSS scheme if you're not EU-established), UK sales need UK VAT registration from the first sale, US sales run state by state, Australian sales trigger GST for non-resident sellers above a threshold, and Canadian sales bring in GST/HST at the federal level plus a provincial layer.

FBA and warehouse inventory raise permanent-establishment risk on their own, separate from sales tax: physical inventory in a country can create a taxable presence there even without a local entity, and while Amazon FBA specifically has generally been treated as not creating PE in a number of jurisdictions, that treatment isn't universal and shouldn't be assumed without checking the specific country.

Entity Setup by Where You Actually Live

• United States
  Typical entity: Delaware or Wyoming LLC (or S-corp)
  Tax outcome: Full US taxation regardless of structure
  Note: Citizenship-based taxation means offshore structures don't help; sales-tax software is essential given the state-by-state picture below

• Europe (staying put)
  Typical entity: Home-country entity, or UK Ltd for English-language convenience
  Tax outcome: Home-country corporate + personal tax
  Note: OSS registration handles cross-border EU sales; genuine relocation is the only route to a materially different outcome if the home country is high-tax

• UAE
  Typical entity: UAE free zone company
  Tax outcome: 0% personal, 0% qualifying corporate
  Note: Requires real UAE presence to be defensible

• Panama
  Typical entity: Panama SA
  Tax outcome: 0% on foreign-source income
  Note: Works cleanly when all customers are outside Panama

• Asia (outside low-tax hubs)
  Typical entity: Home-country entity usually simplest
  Tax outcome: Home-country taxation
  Note: Hong Kong or Singapore sometimes used for regional operations; Chinese sellers carry an added layer of currency-control and reporting compliance

VAT, GST and Sales Tax Thresholds

• EU
  Threshold: €0 for non-EU digital services; €10,000 aggregated for physical goods to consumers
  Registration trigger: OSS or country-by-country above threshold

• United Kingdom
  Threshold: £0 for non-UK sellers
  Registration trigger: Registration required from the first sale

• United States
  Threshold: No single national threshold — see below
  Registration trigger: State-by-state; check each state where you have nexus

• Australia
  Threshold: AUD 75,000
  Registration trigger: GST on non-resident sales above threshold

• Canada
  Threshold: GST/HST at 5–15%, by province
  Registration trigger: Federal plus provincial layer

• Japan
  Threshold: JPY 10 million

• Singapore
  Threshold: SGD 1 million for goods, lower for services

The US Threshold Is No Longer One Number

"$100,000 a year or 200 transactions" used to be a reasonable shorthand for US economic nexus. It isn't anymore. As of August 2026, seventeen states (Alaska, California, Colorado, Illinois, Indiana, Iowa, Kentucky, Louisiana, Maine, Massachusetts, North Carolina, North Dakota, South Dakota, Utah, Washington, Wisconsin and Wyoming) have eliminated the 200-transaction threshold entirely, leaving a revenue-only test. The states that kept some version of it don't agree on the structure either: revenue-only thresholds sit at $100,000 in some states and $250,000 or $500,000 in others, while a minority retain a transaction-count prong either as an "or" alternative to the revenue figure or an "and" requirement alongside it.

There is no longer a typical rule to memorise here — this is a state-by-state question, full stop, and it needs checking state by state rather than applied from a shorthand that used to be accurate. Sales-tax automation software (Stripe Tax, Anrok, Avalara and similar) exists largely because this table changes too often for anyone to track manually.

FBA and Permanent Establishment

Historically, Germany and the UK have treated FBA warehouse inventory as not creating permanent establishment for a foreign seller, subject to the seller having genuine substance and control elsewhere. Other jurisdictions vary, and reforms in the spirit of the US Wayfair decision have generally expanded how much reach tax authorities claim over remote sellers, not reduced it. Separately, and this doesn't resolve the PE question, Amazon itself collects and remits marketplace-facilitator sales tax in most US states on the seller's behalf, which handles the collection mechanics without touching the underlying nexus or PE analysis.

Structuring Mistakes Worth Naming

Ignoring VAT or GST registration thresholds until enforcement catches up costs more than registering early would have. Choosing an entity that doesn't match where your primary customers actually are creates avoidable friction. A personal residency in a high-tax country paired with an entity in a low-tax one triggers CFC rules that erase the benefit. Underestimating the scale of US multi-state sales tax compliance is common precisely because the rules keep moving. FBA inventory spread across multiple countries without a PE analysis is a live exposure, not a hypothetical one. And relying on a single Amazon account without any diversification plan is a business-continuity risk as much as a tax one.

Consolidating as You Scale

Growing e-commerce operations generally converge on one primary entity matched to the owner's actual residency, multi-currency banking (Wise, Mercury, Airwallex or similar), sales-tax automation rather than manual tracking, bookkeeping kept in the reporting currency, a cross-border tax adviser who actually works with e-commerce specifically, and a scheduled jurisdiction review rather than a one-time setup nobody revisits as the business grows.

Find the Exposure Before the Notice Does

Book a scoping call and bring your current entity, your FBA warehouse countries, and your top three customer markets. We'll flag the permanent-establishment and VAT exposure you don't currently know you have.

This is general information current as of September 2026, not personal tax, legal or business advice — US state sales-tax thresholds specifically are changing often enough that you should confirm the current rule in each state before relying on this table.