UK Seller's Guide to German VAT After Brexit

UK companies are now third-country businesses for German VAT, the same as US or Canadian companies. They register directly through a licensed tax advisor, with no fiscal representative and no registration threshold, at Finanzamt Hannover-Nord, which usually takes 4 to 8 weeks; they then file a VAT return (UStVA) monthly or quarterly, as the tax office decides.

What Changed with Brexit

Before the UK left the EU on 31 December 2020, UK companies benefited from the same EU VAT simplifications as any other EU member state business. Distance selling thresholds, intra-EU simplifications, and access to the Mini One-Stop Shop (MOSS) were all available. The post-Brexit reality is fundamentally different.

From 1 January 2021, the UK became a third country under EU VAT law. For UK businesses selling into Germany, this shift has concrete, non-negotiable consequences:

The core principle: the UK is now treated exactly like any other non-EU country. This is not a temporary situation, there is no current UK-EU VAT treaty that would restore pre-Brexit simplifications.

Who Needs German VAT Registration

The obligation to register for German VAT arises the moment a UK company makes a taxable supply in Germany. Here are the most common scenarios:

Amazon FBA Sellers Using German Warehouses

This is the most clear-cut case. If you are a UK seller enrolled in Amazon Pan-European FBA, Amazon stores your inventory in its German fulfilment centres (e.g. in Bad Hersfeld, Rheinberg, or Leipzig). The moment your stock crosses the German border, you have a taxable presence in Germany. Registration is mandatory before you sell a single unit from that inventory.

Amazon’s Pan-EU programme has a direct line between inventory allocation and VAT obligations. If you are in Pan-EU, check which countries Amazon is distributing your stock to, each one may trigger a separate registration obligation.

E-Commerce Sellers Shipping from UK to German Customers via DE Fulfilment

If you use a third-party logistics provider (3PL) in Germany or maintain any form of consignment stock on German soil, you are making supplies from Germany and must be registered. This includes sellers using fulfilment services from platforms other than Amazon (e.g. Zalando Fulfilment, Otto, or independent 3PLs).

UK Companies Providing Services to German Businesses (B2B)

For B2B services, the reverse charge mechanism (Umkehr der Steuerschuldnerschaft, §13b UStG) typically means the German business customer accounts for the VAT, not the UK supplier. In these cases, a UK company providing pure B2B services to German business customers usually does not need to register for German VAT. The German recipient handles the VAT via their own return.

However, this only applies where the service falls under the general B2B place of supply rule. Some service categories are exceptions, if in doubt, check with a tax advisor.

When You Do NOT Need to Register

• Pure B2B services: Advisory, consultancy, digital services, or similar supplied to registered German businesses where reverse charge applies throughout. No German stock, no German establishment.
• Goods sold exclusively to German businesses on DDP terms where the German buyer is the importer of record. If the German buyer imports and pays the import VAT, and you are not storing goods in Germany, there may be no obligation. Specific legal advice is recommended here.
• Sales exclusively via marketplace (with marketplace as deemed supplier): If a marketplace (e.g. Amazon) is deemed the supplier under §3 Abs. 3a UStG, the marketplace may collect and remit German VAT on your behalf for B2C sales, but this does not remove your own registration obligation if you hold stock in Germany.

Registration Process for UK Companies

Unlike EU-based companies, which are typically assigned to the Finanzamt closest to their registered branch in Germany, UK companies (as third-country businesses) are assigned to a specific, centralised office. Finanzamt Hannover-Nord is responsible for all VAT registrations of UK-incorporated companies in Germany. Look up the assigned Finanzamt + IBAN by country →

Documents Required

Finanzamt Hannover-Nord requires the following document set for UK companies:

• Certificate of Incorporation (from Companies House), must be a current copy, typically no older than 3 months
• VAT registration certificate (from HMRC, showing your UK VAT number), if the company is VAT registered in the UK
• Memorandum & Articles of Association, to confirm the company’s structure and authorised signatories
• Passport copies of all managing directors, every director listed in the company’s corporate documents
• Completed Fragebogen zur steuerlichen Erfassung, the German tax registration questionnaire; see our step-by-step English guide to the Fragebogen
• SEPA direct debit mandate, for VAT payment collection by the Finanzamt

No German bank account is required. SEPA transfers from UK banks are accepted. UK banks generally support SEPA credit transfers, so this is rarely a practical obstacle.

Timeline: 4 to 8 Weeks

Registration usually takes 4 to 8 weeks from submission of a complete application to receiving your Steuernummer (tax number). Some tax offices are slower at the moment: see the current figure for each office. The USt-IdNr. (German VAT identification number, starting with “DE”) follows from the Bundeszentralamt für Steuern (BZSt) approximately 1–2 weeks after the Steuernummer.

For a detailed breakdown of the registration process stages and what causes delays, see our article on how long German VAT registration takes.

Applications submitted by a licensed tax advisor tend to process faster. Incomplete applications are the leading cause of delays, a single missing document restarts the processing clock.

Ongoing Compliance Obligations

Once registered, UK companies have the same ongoing obligations as any other foreign company registered for VAT in Germany. Here is what that looks like in practice:

Monthly UStVA (Advance VAT Return)

Monthly filing applies when your German VAT is over €9,000; you file monthly or quarterly, as the tax office decides. It is not an automatic first-two-years rule: that rule (§ 18 Abs. 2 Satz 4 UStG) is suspended for the tax periods 2021 to 2026, so a new registration’s first year follows the VAT it expects to owe. The monthly Voranmeldung must be submitted electronically to the Finanzamt. Paper filings are not accepted for foreign companies. The filing deadline is the 10th of the month following the reporting period, for example, the January return is due by 10 February.

If you apply for a permanent filing extension (Dauerfristverlängerung), the deadline shifts to the 10th of the second following month, but this requires a deposit equal to 1/11th of the prior year’s VAT liability.

Quarterly filing applies when VAT liability is at or below €9,000, and because the automatic monthly rule for new businesses is suspended for the tax periods 2021 to 2026, even a first year can be quarterly if the VAT you expect stays under that line.

Annual Declaration (Umsatzsteuerjahreserklärung)

In addition to monthly returns, an annual VAT declaration must be filed by 31 July of the following year (or 28/29 February of the year after that if filed through a tax advisor, subject to applicable extension rules). The annual declaration reconciles all monthly returns filed during the year.

ZM (Zusammenfassende Meldung), Not Required

The EC Sales List (Zusammenfassende Meldung or ZM) is a reporting obligation for intra-EU B2B supplies. Since the UK is no longer an EU member state, UK companies do not file ZM reports for their UK-Germany transactions. Intra-EU supplies between a UK company and a German company are not “intra-EU” by definition, they are imports/exports. No ZM obligation arises.

Intrastat, Not Required

Intrastat is a statistical reporting system for goods movements between EU member states. Since the UK is outside the EU, UK companies moving goods to Germany are making imports, not intra-EU movements. Intrastat declarations are not required. Instead, customs declarations (import entries) govern the goods flow. You will need an EORI number (both a UK EORI for export from the UK and a German/EU EORI or your tax identification for import into Germany).

Common Mistakes UK Sellers Make

These are the errors we encounter most frequently when UK companies come to us for help, often after problems have already arisen:

Assuming OSS Covers Germany

The EU’s One-Stop Shop (OSS) scheme allows EU-based sellers to report VAT on B2C distance sales across all EU member states through a single return in their home country. UK businesses are not eligible for OSS, it is exclusively for EU-established businesses. A UK seller cannot use the Irish, Dutch, or any other EU OSS registration to cover their German VAT. There is no workaround: if you have a German VAT obligation, you must hold a German registration.

Not Registering When Using Amazon Pan-EU

Amazon Pan-European FBA automatically distributes your inventory to fulfilment centres across the EU, including Germany, to optimise delivery speeds. Many UK sellers enrol in Pan-EU without realising that having stock in a German warehouse is an immediate VAT registration trigger, regardless of whether you have made a single sale to a German customer. The obligation arises from the storage of goods in Germany, not from the sales. See our Amazon VAT Germany guide for the full picture.

Missing the EORI Number Requirement

Goods shipped from the UK to Germany must clear customs. This requires an EORI (Economic Operator Registration and Identification) number. UK sellers need a UK EORI (for export out of the UK). On the EU side the declaration is normally filed by their forwarder on its own EORI, so most need no EU EORI of their own. Without a valid EORI, goods will be held at customs. This is a separate requirement from VAT registration but equally non-negotiable for physical goods sellers.

Paying for a Fiscal Representative When One Isn't Needed

Germany does not require non-EU companies to appoint a fiscal representative for standard VAT registration and filing. Under § 22a UStG, fiscal representation is an option, not a duty, and it is open only to a business that makes exclusively tax-free supplies in Germany. A licensed tax advisor acting as your tax agent is sufficient. If a quote includes fiscal representation, ask which rule makes it necessary in your case. See our detailed breakdown in Fiscal Representative Germany: Do Foreign Companies Need One?

Michael Stiller, Steuerberater (licensed German tax advisor)

Files your German VAT returns with the Finanzamt

Written by Michael Stiller, licensed German tax advisor (Steuerberater) and founder of FRADECO GmbH, the tax advisory firm that runs Vaytax and files German VAT returns with the Finanzamt (tax office) for foreign sellers.

About Michael Stiller → · How we write and review our guides →