When carrying out taxable activity in Germany you are required to register for German VAT prior to the activity taking place. It can take up to 12 weeks to get a VRN in Germany so you should plan ahead to ensure you are compliant and avoid additional fees.
When should you register?
There are a number of trading situations where you should register for German VAT, these are some of the broad scenarios;
- Importing goods into Germany from another country, either from within the EU or from outside the EU
- Intra-community supplies & acquisitions
- Buying and selling goods in Germany
- Selling goods over the internet to German consumers, subject to the EU 10K EUR distance sales threshold
- Goods held in consignment stock
- Holding live exhibitions, events or training in Germany
- If a company is otherwise a non-VAT trader, but is receiving services in Germany under the reverse charge rule
- The self supply of goods
It is unlikely you would need to register for VAT in Germany if you are providing services local to German companies, and instead you can use the German Reverse Charge process. Providers of electronic, broadcast or telecomes services to consumers in Germany can also take advantage of the new OSS Scheme (previously MOSS) to file a single return for all 27 EU countries without having to VAT register.
The scheme is also available for goods which are stored within Germany to avoid VAT registration in the other EU countries but a German VAT number is required due to storage.
What format is the German VAT number?
Once the registration has been granted you will receive two identification numbers in Germany.
- Steuernummer, which is a general tax number which is used by the tax authorities in their supervision of any trader, including VAT returns. This is received first.
- USt-IdNr, which is a VAT identification number for the reporting of intracommuity supplies. This is provided following receipt of the Steuernummer by the Federal Finance Office.
The Steuernummber format is typically 25/249/12345
The USt-IdNr format is typically DE123456789
German F22 Certificate for Marketplaces
The F22 certificate was introduced by Germany for NON-EU sellers on 1st March 2021 and for EU sellers on 1st October 2021
The F22 Certificate is obtained via an application to the various German tax offices, and must be presented to any digital marketplace to ensure the right to continue to promote products on the platform. Marketplaces will block any seller who is not in possession of a F22 VAT Certificate. If the marketplace does not verify the F22, and continues to allow the seller to trade on their platform, then they may be held liable for any unpaid German VAT.
A formal request from the European Commission to Germany was made for the removal of the F22 certificate as it is seen as inefficient and disproportionate measure that hinders the free access of EU businesses to the German market in violation of EU Law. The EC points out the member states have agreed much more efficient anti-VAT fraud measure for 2021.
From July 1st 2021 the F22 certificate will no longer be required to sell on Marketplaces and instead you will just need to upload your German VAT Identification Number