VAT Compliance Germany – A Practical Guide for Polish Companies 2026

Are you selling to Germany and unsure if you are already obligated to register for VAT? Or perhaps you know you should take action, but the language barrier and complex regulations cause you to postpone it? VAT compliance in Germany is one of the most common challenges for Polish entrepreneurs entering the DACH market. It is also one of the most costly to ignore – German tax authorities verify sellers on marketplace platforms and can audit up to 10 years retroactively. This guide provides you with concrete answers, figures, and steps.

When does the VAT obligation arise in Germany?

The obligation to register for VAT in Germany may arise even if your company has no registered office or branch there. What matters is what you sell and how you sell it – not where you are formally registered.

The EUR 10,000 threshold and the OSS rule

If you sell goods or digital services to consumers (B2C) across the EU and your total cross-border turnover has not exceeded EUR 10,000 in the current or previous year, you can account for VAT in Poland through the VAT OSS procedure. Once this threshold is exceeded, you have two options: register locally in each country or join the OSS.

Note: The EUR 10,000 threshold is cumulative for the entire EU, not just Germany. If you sell to several countries, all turnovers are added together.

When registration in Germany is mandatory regardless of the threshold

In the following situations, you must register for VAT in Germany regardless of your turnover:

SituationRegistration obligation
Storing goods in Germany (e.g., Amazon FBA, own warehouse)✅Yes, from day one
Selling via Amazon.de and using FBA✅Yes, from day one
Providing construction or installation services in Germany✅Yes
Organizing events or training on-site in Germany✅Yes
Conducting B2C sales via an independent online store and exceeding EUR 10,000✅Yes
B2B sales under the Reverse Charge mechanism❌No (VAT is accounted for by the buyer)

Numerical example: You have an online store and in 2025 you sold goods to Germany for EUR 6,000 and to France for EUR 5,000. Total: EUR 11,000 – you have exceeded the EUR 10,000 threshold. From this point on, you are obliged to register for VAT in Germany or join the OSS.

Amazon FBA – a special case

If you send goods to an Amazon warehouse in Germany (e.g., a fulfillment center in Bavaria, Saxony, or Brandenburg), the physical goods are located on DE territory. This triggers a VAT registration obligation from the very first unit of goods – without any thresholds. Amazon will not register on your behalf. If you sell on Amazon.de, use FBA, and do not possess a DE VAT number, you are operating illegally.

How to register for VAT in Germany – step by step

VAT registration in Germany is done by correspondence – you do not need to travel to Germany. The entire process typically takes 4-8 weeks, provided the documents are complete and correctly filled out.

Which tax office is competent?

Polish companies register for VAT in Germany at a tax office determined by the first letter of the enterprise’s name:

First letter of company nameCompetent tax officeAddress
A – GFinanzamt HamelnSüntelstraße 11, 31785 Hameln
H – LFinanzamt OranienburgStralsunder Str. 2, 16515 Oranienburg
M – RFinanzamt CottbusVom-Stein-Straße 29, 03050 Cottbus
S – ZFinanzamt NördlingenHallgasse 5, 86720 Nördlingen

List of documents for VAT registration in Germany

  1. Fragebogen zur steuerlichen Erfassung – the main registration application (available on the Bundesfinanzministerium website), must be completed in German.
  2. Vollmacht – power of attorney, if the registration is performed by an accounting firm or tax advisor on your behalf.
  3. CEIDG excerpt (sole proprietorship or civil partnership) in English or with a standard translation.
  4. KRS excerpt (National Court Register) translated by a sworn translator into German (commercial companies).
  5. Articles of association / deed of incorporation with a standard translation into German.
  6. Copy of the EU VAT registration confirmation (EU number).
  7. Confirmation of bank account ownership – preferably an EUR currency account.
  8. Copy of the passport or ID card of the owner / company representative.

Note: Documents no. 4 and 5 require a sworn or standard translation – check with the specific office to be certain. Incorrectly translated documents can delay the entire process by several weeks.

Timeline of the registration process

  • Weeks 1-2: Collating and translating documents
  • Week 3: Dispatching documents to the competent Finanzamt
  • Weeks 4-8: Waiting for the authority’s response
  • Weeks 8-10: Receipt of the Steuernummer by post at the company’s or proxy’s address
  • Weeks 10-14: Application for the USt-IdNr (after receiving the Steuernummer)

If the tax office has additional questions, it will request supplementary documents – this can extend the process by another 2-4 weeks.

Steuernummer vs USt-IdNr – two numbers, two applications

Upon VAT registration in Germany, you will receive two different tax numbers. Confusing them is one of the most common mistakes made by Polish companies – and can result in invoice rejection.

FeatureSteuernummerUSt-IdNr (Umsatzsteuer-Identifikationsnummer)
Formate.g., 12/345/67890e.g., DE123456789
PurposeCommunication with the tax office, VAT returnsB2B invoices, intra-Community transactions
When do you receive itAfter completing registration (~8 weeks)Upon request, after receiving the Steuernummer
Is it public?NoYes – can be verified in VIES

Practical rule: On an invoice to a German B2B contractor, always provide the USt-IdNr – both yours (Polish) and theirs (DE). The Steuernummer should only be provided in communication with the authorities and in VAT returns.

Verification of the contractor’s VAT number

Before issuing a Reverse Charge invoice, always check if the contractor’s VAT number is active. The VIES system, maintained by the European Commission, is used for this purpose. Verification is free and simply requires entering the number in the DE + 9 digits format.

VAT rates in Germany 2026

Germany applies three VAT rates (Umsatzsteuer / Mehrwertsteuer):

RateValueApplication
Standard19%Most goods and services
Reduced7%Food, books, press, public transport tickets, cultural services
Zero0%Exports outside the EU, intra-Community supplies of goods (WDT)

Examples of rates for e-commerce

  • Electronics (smartphones, laptops, accessories) → 19%
  • Clothing and footwear → 19%
  • Unprocessed food → 7%
  • Dietary supplements → 19% (note: often misclassified)
  • E-books and audiobooks → 7% (since 2020, equated with physical books)
  • Software as a Service (SaaS) → 19%

Important: Applying the incorrect VAT rate is your responsibility as the seller. If you charge 7% instead of 19%, the tax office will charge you the difference – along with interest. In case of doubt regarding the rate for a specific product, check the official classification of the Bundeszentralamt für Steuern.

VAT returns in Germany – deadlines and rules

After registering for VAT in Germany, you are obliged to submit regular VAT returns. Germany has one of the most formalized VAT reporting systems in the EU.

Types of returns

Umsatzsteuervoranmeldung (UStVA) – preliminary return, submitted monthly or quarterly.

  • Monthly – if your VAT liability in the previous year exceeded EUR 7,500.
  • Quarterly – if the VAT liability was between EUR 1,000 and EUR 7,500.
  • No advance payment obligation – below EUR 1,000 (only an annual return).

Umsatzsteuererklärung – annual VAT return, submitted by July 31 of the following year (if using a tax advisor, the deadline is extended to the end of February of the subsequent year).

Deadline for preliminary returns

The monthly or quarterly return must be submitted by the 10th day of the month following the settlement period. Example: return for January → deadline February 10.

Dauerfristverlängerung – a one-month filing extension

Germany allows for a permanent one-month extension of the filing deadline. This instrument is called Dauerfristverlängerung and can be requested via the Elster system. In exchange, an advance payment (Sondervorauszahlung) amounting to 1/11 of the total VAT from the previous year is required. For companies with irregular sales, this is often a cost-effective solution – granting an additional 4 weeks to gather documents.

Elster – the online filing system

VAT returns in Germany are submitted exclusively electronically via the Elster Online portal. Foreign companies without a registered office in Germany can use Elster after registration – or mandate a tax representative (steuerlicher Vertreter) to file returns.

If you do not have a permanent proxy in Germany, filing returns via Elster requires an account activation process taking several weeks. It is worth anticipating this well before the first deadline.

What must a German VAT invoice contain?

An invoice issued for transactions subject to VAT in Germany must comply with the requirements specified in §14 UStG (Umsatzsteuergesetz). The omission of any element may result in the contractor being denied the right to deduct VAT.

Mandatory invoice elements

ElementGerman termRemarks
Full name and address of the sellerVollständiger Name und Anschrift des Leistenden
Full name and address of the buyerVollständiger Name und Anschrift des Leistungsempfängers
Seller’s VAT numberSteuernummer or USt-IdNr des Leistenden
Buyer’s VAT number (B2B)USt-IdNr des LeistungsempfängersRequired for intra-Community transactions
Date of issueAusstellungsdatum
Sequential invoice numberFortlaufende RechnungsnummerMust be unique
Description of goods/servicesMenge und Art der LeistungMust be specific, not “marketing services”
Delivery or service execution dateLiefer- oder LeistungsdatumMust be entered even if it coincides with the invoice date
Net amountNettobetrag
Applied VAT rateSteuersatz19%, 7% or 0%
VAT amountSteuerbetrag
Gross amountBruttobetrag
Legal basis for exemption (if applicable)Hinweis auf Steuerbefreiunge.g., “Reverse Charge”

Reverse Charge invoice

For B2B sales to a German VAT taxpayer, where the liability to account for VAT shifts to the buyer, the invoice must contain the annotation:

“Steuerschuldnerschaft des Leistungsempfängers” (Reverse Charge)

You display the net amount without VAT on the invoice. The buyer independently accounts for the VAT on their end.

VAT refund from Germany

If the input VAT (from purchases, expenses, imports) exceeds the output VAT (from sales), a refundable surplus arises. This is a frequent situation with intensive goods procurement in Germany or high logistics costs.

How to get a VAT refund?

You declare the surplus in the UStVA return. The tax office refunds it to the indicated bank account. You can also request that the surplus be credited towards future liabilities.

How long does a refund take?

  • Standard: 6-8 weeks from the date of filing the return
  • During a tax audit (Betriebsprüfung): up to 6 months or longer
  • After 15 months without a refund: the authority is obliged to pay interest at a rate of 1.8% annually.

Tax offices in Germany often withhold refunds and initiate audits on the first returns of a new foreign company. This is standard procedure – it does not imply anything is wrong. It is highly advisable to have your purchase documentation ready.

VAT refund for companies without DE registration

If you incur costs in Germany (e.g., trade fairs, hotels, fuel) but have no VAT registration obligation there, you can claim a refund under the Refund Directive 2008/9/EC via the VAT Refund portal in your country of registration. Deadline for the application: September 30 of the following year.

Penalties for lack of registration or errors

Germany conducts systematic verification of foreign sellers – particularly on Amazon and eBay platforms (data from platforms has been transmitted to authorities since 2019 under §22f UStG). Ignoring the VAT obligation in Germany poses a risk that escalates with each month of arrears.

Financial penalties

ViolationPenalty
Lack of VAT registration = tax arrearsOutstanding VAT + 1.8% annual interest + fine up to EUR 50,000
Late return (Verspätungszuschlag)10% of the VAT amount, min. EUR 25, max. EUR 25,000
Unintentional incorrect return1.8% annual interest on the arrears
Intentional tax evasion (Steuerhinterziehung)Fine or imprisonment up to 5 years
Incorrect VAT rate on invoicePayment of the difference + interest

Statute of limitations

  • 4 years from the end of the year in which the tax liability arose – standard period.
  • 10 years – for intentional tax evasion.

Example: A company has been selling via Amazon FBA since 2022 without a DE VAT number. In 2026, the tax office verifies data from Amazon. It can go back to 2022 and demand outstanding VAT + interest + fines for 4 years. With monthly revenues of EUR 20,000, the total amount can exceed EUR 150,000.

Voluntary disclosure (Selbstanzeige)

If you have arrears and wish to settle them before the tax office finds you, you can file a voluntary disclosure (Selbstanzeige). If deemed effective, it allows you to avoid criminal liability – though it does not exempt you from paying the outstanding tax and interest. This solution requires careful preparation with a tax advisor.

VAT deregistration in Germany

If you have ceased selling to Germany or stopped storing goods there, you can deregister from VAT in Germany. The procedure is formal and requires a written application.

When can you deregister?

  • You have terminated the activity triggering the registration obligation (e.g., closed the FBA account in Germany).
  • Your turnover has permanently dropped below the threshold, and you are using the OSS.
  • You have liquidated the company.

How does deregistration work?

  1. Submit a written application (Abmeldung) to the competent Finanzamt.
  2. File all outstanding VAT returns for the periods you were registered.
  3. Settle any tax arrears.
  4. The authority confirms deregistration by post – waiting time: 4-12 weeks.

Note: Merely ceasing sales does not trigger automatic deregistration. As long as you are formally on the DE VAT register, you must file returns (even zero-value ones). Failure to file returns after ceasing sales generates penalties.

Summary

VAT compliance in Germany is not a one-off formality – it is an ongoing obligation encompassing registration, monthly or quarterly returns, proper invoicing, and timely payments. For companies selling via Amazon FBA or conducting distance sales to Germany, it is one of the first and most critical steps towards legally operating in this market.

Last update: January 2026. The information contained in this article is of a general nature and does not constitute tax advice. In case of individual doubts, consult a tax advisor.


Opinions about us



They trusted us


Efekta Blog


Contact us!

Don’t wait – take advantage of modern accounting, HR, payroll, tax, legal, and insurance services designed to help you achieve your business goals.

Call +48 22 403 40 98, +48 604 501 507
Write to: biuro@efekta.waw.pl
Book your free online consultation – find out how we can support your business!

Request a free quote

Frequently asked questions

Do I need DE VAT when selling via Amazon.de even below EUR 10,000?

Yes – if you use FBA and your physical goods reside in an Amazon warehouse in Germany, you must register for VAT regardless of turnover. The EUR 10,000 threshold strictly applies to distance selling from Poland (goods shipped directly to the customer without storage in DE).

How much does VAT registration in Germany cost?

The registration itself at the tax office is free. The costs involve sworn translations of documents (PLN 100-300 per document) and the fee for the accounting firm or advisor if outsourced (typically PLN 1,000-3,000 as a one-time fee).

How long does it take to get a VAT number in Germany?

With a complete and accurate application: roughly 4-8 weeks for the Steuernummer, plus another 2-4 weeks for the USt-IdNr. In practice, the entire process from issuing documents to obtaining both numbers takes 2-3 months.

What is the Kleinunternehmerregelung and does it apply to me?

Kleinunternehmerregelung is a German relief for small businesses – it exempts companies whose turnover in Germany did not exceed EUR 22,000 in the previous year and EUR 50,000 in the current year from charging VAT. However, as a Polish company registering for VAT in DE, you generally cannot benefit from this relief – it is reserved for entrepreneurs established in Germany. Exceptions are rare and require verification by an advisor.

Must I have a tax representative in Germany?

There is no statutory obligation for EU companies to appoint a tax representative (steuerlicher Vertreter). In practice, however, filing returns independently without knowledge of the language and the Elster system is extremely difficult. A representative facilitates communication with the authority and ensures timely filings.