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Amazon.de Germany’s VAT Tax Certificate/Declaration issue FINALLY SOLVED!

April 18, 2019 by Andrew Minalto - 48 Comments
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Let’s talk taxes. Yes, I know, I know! One of the most popular topics of all time, especially when it comes to Amazon and VAT. As much as I would like to not think about it and go into the head-in-sand mode, the reality is that we simply can’t avoid the issue of tax. Moreover, with the recent changes in how Germany handles VAT, we now have no choice but to face the issue head-on and find an effective solution.

I have already created a very detailed post about VAT for Amazon sellers, and it has quickly become one of the most popular posts on the blog. I have covered the basics of how VAT works in that post, so I won’t repeat that information here today.

This particular article is all about the newly created VAT situation in Germany, how it will affect Amazon sellers (especially those of us based on the UK), and what you need to do to stay compliant and not lose your seller account.

Just a quick disclaimer before we move forward:

I’m not a tax advisor, accountant or international law specialist. Everything I write in this post is purely my own observations and nothing more. DO NOT use this as legal advice under any circumstances! If you feel that you’re not comfortable with this information, seek legal advice.

Ok, with that disclaimer taken care of, let’s jump right into it! Firstly, if you’re new to selling on Amazon, you might be wondering what all the fuss is about. Let’s find out!

Germany’s new Marketplace
VAT liability LAW

On November 9th 2018, the German Parliament passed a new law that makes online marketplaces potentially liable for unpaid VAT by third-party merchants on their platforms.

In simple terms, the German government was fed up with missing out on all the tax money generated by online sales, so they took action and introduced this new law. The new law basically makes online marketplaces LIABLE for their sellers’ VAT tax obligations. And by online marketplaces, they basically mean eBay and Amazon.

Previously, eBay and Amazon basically told the government that they can’t know what their sellers do, they can’t police them to pay tax, etc., but now, with this new German law, there are no more excuses. The German tax authorities can and most likely WILL follow through on this and hold these large marketplaces accountable for their sellers’ unpaid VAT.

So, what are the actual VAT obligations for the everyday Amazon seller in Germany?

As I already explained in my ultimate VAT guide for Amazon sellers, there are certain criteria for when you need to register for VAT in Germany and start doing tax returns there. I am looking at this from a UK perspective, but if you live in any other EU country, the same rules will apply to you. The criteria are:

  • You store inventory and fulfill orders from Germany. This basically means that when you start using Amazon’s Pan-European program OR if you selectively sell on Amazon.de and send your stock to Germany, you’re obligated to register for VAT in Germany. This is nothing new and this law has been in place for years.
  • Your sales to German customers exceed €100,000 per year across all sales channels. fulfil is the distance sales threshold and is calculated per CALENDAR year —it is NOT a rollover of the last 12 months. Again, this law has been in place for years now, so it’s nothing new.

So, if you (or Amazon) send goods to Germany and store them there for order fulfilment, you need to register for VAT in Germany. Also, if in any calendar year, your TOTAL COMBINED sales across all channels (eBay, Amazon, online shop, etc.) goes over the 100k EUR threshold, you need to register for VAT.

All basic stuff, right? So what’s the problem?

The problem is that with the new German law, marketplaces (Amazon, eBay, etc.) are now responsible for ensuring their sellers meet these regulations, AND, if they can’t do a good job on this, they can even be held liable for any unpaid taxes. We won’t cover the mechanics of this, but detailed in the new law are the procedures marketplaces will have to follow, the data that will need to be collected and shared with German tax authorities, etc.

Before this new law came into effect, Amazon had already started to ask for VAT numbers for sellers in their Pan-European program, as it allowed them to easily see/track which sellers store goods in other European countries. They even introduced special VAT programs and initiatives for sellers, covering the cost of VAT registration numbers and tax returns for one whole year. This is the program I am personally currently involved with, and I will be doing a separate post on it soon when I receive all the VAT numbers.

Up to this point, everything is relatively simple. If you have stock in a country, you need a VAT number there.

The problem starts with the €100k distance sales threshold. Of course Amazon can easily see the value of the sales you make to German customers in any given year, BUT they don’t know what you’re also doing outside of the Amazon platform!

It could be that you only sell €10k worth of products to Germany via Amazon, while simultaneously selling €150k worth of products via eBay! Combined, that would be €160k—way beyond the threshold—but how would Amazon know that?

In this example, your numbers would most likely be caught by eBay as they will see that your sales are over €100k on their platform alone, but what about scenarios where sellers don’t reach that threshold on any one platform?

Let’s take a look at another scenario: your sales to Germany are €70k via Amazon and €60k via eBay. Combined, you have sales to Germany to the value of €130k, so you definitely need to register for VAT. However, neither Amazon or eBay can know that you have reached this threshold as they don’t share such data with each other.

With the new law in place, in a scenario like this, both Amazon and eBay are responsible for this tax evasion situation and can be held accountable. I don’t know how it could be enforced in reality (and there’s most likely a procedure where sellers are still the FIRST person to be punished/fined, etc.) but it doesn’t change the fact that the days of Wild West VAT are well and truly coming to an end, and things are changing for sellers very quickly.

Very soon, almost every seller doing business in the EU will need to register for multiple VAT numbers in various countries. Luckily, in the very near future (2021 or 2022), the EU will introduce a brand-new VAT system that will eliminate this problem altogether. EU sellers will be able to do VAT calculations from one place, in one country, for sales across all of the EU (just like we currently do with digital products).

But until that happens, we need to go through the costly and time-consuming process of registering for VAT numbers in each and every country separately, starting with Germany—or do we? Do we actually need to register for VAT in Germany? Let’s sort this out once and for all!

Amazon.de German
VAT Certificate Drama

If you’re already selling on Amazon, you will know this story very well as it has been talked about over and over on the Amazon Sellers forums, various blogs, and even within my Amazon Sharks Facebook group.

To cut a long story short, Amazon initially interpreted the new law in a way that required ALL sellers to upload a German tax certificate. If you don’t comply with this requirement, you can’t sell to Germany anymore. Yes, even if you didn’t store goods in Germany via the Pan-EU program or directly, Amazon still wanted you to upload the tax certificate.

This created massive chaos on Amazon and uproar in seller communities because many (I assume the majority) sellers didn’t actually need or have a tax certificate as they didn’t exceed the €100k per annum distance selling threshold. And they didn’t store any goods in Germany.

I do understand why Amazon did it, though. Just like I explained, under the new German law, marketplaces are held liable for third-party VAT evasion, so they took the obvious route and removed all responsibility from their shoulders by simply asking everyone to register for VAT in Germany.

It was only when the last-minute deadlines were approaching that Amazon suddenly changed their stance on this. I don’t know if they found a loophole in the system or their lawyers found a way around it, but luckily for us, they did change their approach and requirements. Now, you may still need to register for VAT in Germany, but only if you meet ONE or both of these two requirements:

  • You keep stock in Germany.
  • Your sales to Germany across all channels are more than €100k per calendar year.

If you don’t meet at least ONE of these requirements, you don’t need to register for VAT in Germany.

I do feel sorry for all the people who, in the middle of the chaos, started and completed the VAT registration process in Germany. They thought it was the only way out, even though they didn’t need it. If you’re one of those people, don’t forget that you can deregister from VAT quite easily. If you feel that you won’t need that German VAT number any time soon, just deregister to avoid having to do regular VAT returns there.

For everyone else, here’s what you need to do…

German Tax Declaration

When Amazon changed their mind on the whole situation, they created a special German Tax Declaration that basically states that sellers are not obligated under the new law to have a VAT number in Germany.

You can find this declaration via your Seller Central account under Tax Settings or by going there directly via this link:

This is the actual text taken from that page:

German tax declaration

This declaration applies to selling partners who are legally established in non-European Union countries, who are not required to be tax registered in Germany.

For selling partners who are not carrying out taxable sales according to the provisions of the German VAT Code and are therefore not required be tax registered in Germany and to obtain a German Tax Certificate, Amazon, as a marketplace operator, must obtain this declaration if you wish to continue to sell goods to customers in Germany. The declaration asks you to confirm relevant facts that show you have no tax registration obligation in Germany.

Exclusive shipments from places outside of Germany:

  1. I am not generating taxable sales in Germany by delivering goods from a German warehouse or any place in Germany. I exclusively ship goods from places outside of Germany.
  2. If I ship goods directly from outside the EU to German customers for all these shipments there is no tax liability in Germany since the conditions specified in Section 3 para 8 German VAT Code are not fulfilled.
  3. If I ship goods stored in other EU countries and deliver directly to German customers all such deliveries are less than 100,000 EUR in the current calendar year and have been less than 100,000 EUR in the previous calendar year (according to Sec. 3c para. 3 German VAT Code)
  4. I will inform Amazon immediately as soon as I exceed the threshold of 100,000 EUR for the first time in a calendar year based on my sales on any marketplace.

The first sentence actually makes you believe that this is only for non-EU sellers:

This declaration applies to selling partners who are legally established in non-European Union countries, who are not required to be tax registered in Germany.

However, I think there’s a mistake or formatting issue (missing and/or) OR they’re playing games? Slightly different versions of the information appear in various FAQ/help pages and, on every page, Amazon clearly state that they don’t provide legal advice, you need to consult a tax advisor, etc.

I still don’t understand how such a simple declaration can be enough to take the responsibility fully off of Amazon’s shoulders. The new German law is very clear on the fact that the marketplaces can and will be held accountable.

I don’t know what games Amazon are playing here, but luckily for us sellers, this is a quick and easy way out of the German VAT situation. Simply log into your account, ACKNOWLEDGE this declaration, and you’re good to continue selling to Amazon customers in Germany—as long as you don’t store stock Germany OR reach the €100k sales threshold per calendar year.

You can learn more about the technical process of registrations and this declaration via this helpful FAQ page.

The deadline to acknowledge this declaration for EU sellers is October 1st, 2019, so there’s no rush. I personally haven’t done it yet. I do plan to store stock in Germany, so I am waiting for my German VAT number to come through.

However, if you don’t plan on doing this and you can’t see your sales exceeding €100k this year, you can safely acknowledge the declaration and forget about this whole thing. Well, for now at least. In truth, no one knows for sure how this will play out in the future and whether Amazon has actually done it the right way. It’s quite possible that they are simply taking a HUGE bet on tax liability right now.

What matters today, though, is that if YOU stay within the line of the law and are not required to be VAT registered in Germany, you’re not at risk. You’re not breaking any laws. The new VAT tax law targets marketplaces specifically and they’re the ones that need to sort their game out and put a simple system in place to eliminate tax evasion.

Ok, that’s it for today! I really hope that I have managed to explain the whole German VAT situation in a simple, easy-to-understand way. If you have any questions, feel free to leave them below the post and I will do my best to help you out. But, again, please note my earlier disclaimer: I’m not an accountant and can’t help with complicated or specific tax situations.

If you’re new to selling on Amazon or new to the whole VAT thing, I highly recommend you check out my ultimate VAT guide for Amazon sellers first.

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  1. Hi! Thank you for your information. We are a self-fulfilled warehouse in France and I have been selling for about a month. I received an email to accept the declaration, and the same day, my account was deactivated. I accepted the declaration and my account is still deactivated. We do not have 100,000,00 EUR in sales, and we do not ship from Germany, so I thought my account would be reactivated. Any suggestion? Thank you again for your insight.

    1. Andrew Minalto

      Hi Sheila,

      You need to register for VAT in German to be able to sell there.

      The declaration thing doesn’t work anymore (as far as I’m aware).


  2. Hi Andrew

    I am happy to discover your site, it is very enriching with all your explanations!

    I am a saler on Amazon based in France and I stock everything in France

    I looked for the answer to my question, but I couldn’t find it.

    Everyone knows that the sales threshold for registering for German VAT is 100,000 euros, but Amazon blocked my account even though I only made only one sale (25 euros) on amazon.de (since the beginning of 2020).

    I wrote to amazon and explained that I am not obliged to register for german VAT, but no reply from them…

    Now I am going to register in Germany but I have a question:

    can I declare 0 euro each month on the ELSTER website, since the 100.000 euro threshold is not reached? How does it work now that I am registered and have very few sales on amazon.de?

    thank you very much

    1. Andrew Minalto

      Hi Alex,

      Thanks for your comment.

      Yes, Amazon requires all sellers to be registered for tax in Germany (even though in theory that’s not always required).

      I don’t know the ins and outs of doing VAT returns in Germany, sorry. All my VAT returns are done by an accounting company called VATGlobal.com


  3. Hi there
    i have also been Deactivated from the DE site, apparently because i store stuff in Germany, this is not the case but i am signed up for Pan European FBA which i think is the problem area ! , i have always had problems selling on the De site don’t know why.
    But i am also selling on the other sites FR/SP and they currently don’t require a French or Spanish Vat certificate !, don’t want to turn off Pan euro FBA for DE as it turns off everyone FR and SP as well , not sure what to do now ?

    1. Andrew Minalto

      Hi Simon,

      Thanks for your comment.

      If you’re using PAN-EU program, you HAVE to have VAT numbers in Germany, Spain, France, Italy, Poland and the Czech Republic.

      I don’t really know how you have been able to sell without VAT registrations, but you need to register for VAT in all those countries to use that program.


  4. Hi Andrew

    Thanks for your post. My German account was also deactivated a week ago. I tried to contact seller support by explaining I’m not liable for German tax registration, but received no reply. I have never made a single sale on Amazon.de, and my main market place is Amazon.co.uk. If I don’t do anything with the German account and leave it deactivated, will it affect my UK account? I’m not too bothered about selling in Germany, but can not lose the ability to sell in UK. Your advise is appreciated.

    1. Andrew Minalto

      Hi Eve,

      No, it shouldn’t affect your account in the UK.


  5. I’m on the phone with Amazon now for the 3rd time on 2 weeks. Still no resolution. Amazon launched this Assault on sellers without warning or a solution. They stopped my sales loosing me valuable income and did it on the day I was supposed to get paid for my previous sales.

    What a complete mess and not a joke to small businesses that rely on Amazon for sales.

    Is Amazon Germany on Financial Trouble so it needed to withhold payments and stop sales?

    I’m disgusted having made this declaration in October 2019 already, when they did the same thing.

    1. Andrew Minalto

      Hi There,

      Didn’t you receive a warning about this in advance?

      I know that other sellers received emails months before Amazon closed their German accounts so they had time to get the registration done.


  6. tom hughes

    Hi Andrew, great info as always, thanks
    Like many others I spent a lot of time and effort looking in to this. I was ready to employ a tax advisor and register in all the countries required. However, during a webinar with one of Amazon’s ‘tax specialists’ the issue of VAT already paid to HMRC came up. For example, a seller has paid VAT to HMRC for 5 years on sales made via Amazon.de. Now Germany want to backdate and have it paid to them. Leaving the poor seller paying VAT twice for historical sales.

    We submitted the declaration anyway so that we could do merchant fulfilled orders and keep our sales under 100k. However, Amazon are still asking for the tax cert and will not reopen our .de account until we do. We have not stored any products in amazon in the last calendar year and we did not go over 100k in sales. Frustrating

    1. Andrew Minalto

      Hi Tom,

      Thanks for your comment.

      Yes, since writing this post, the situation has changed. Basically Amazon now asks all sellers to register in Germany, they don’t care about that declaration anymore…

      So if you want to sell in Germany, you will have to register.


  7. Mehmet Beyazoglu

    hello Andrew
    thanks for this informative post. I am doing fba from England. My Germany account has been blocked. I did what you said in the comment and I approved the German tax declaration.
    -will amazon return to me? or should I open a case for this?

    thanks in advance for your reply

    1. Andrew Minalto

      Hi There,

      Thanks for your comment.

      When did that happen? Basically, for now, in 2020, to sell on Amazon.de using FBA in Germany, you need to register for a VAT number in Germany.


  8. Hi Andrew,

    Thanks for this. Not sure why sellers weren’t informed about this declaration? When I signed up to sell on Amazon in July 2019, I got a European Unified account but never sold or listed or had any inventories placed outside of UK. But a few days ago my Germany account has been suspended? Which is odd considering we never sold anything to Germany. Seller Support hasn’t been helpful. They said I can’t remove EU Marketplaces from my Amazon Uk accounts because it’s a unified account. Silly really. Now I’m worried our UK account will be suspended because I was told when 1 account is suspended, the rest will follow suite.

    Not sure how to go about about this.

    1. Andrew Minalto

      Hi Como,

      Thanks for your comment.

      No, your UK account won’t be suspended – I have never heard of anyone getting the UK account suspended because of the German account suspension.


  9. Hi Andrew, Thank you for taking the time to show so many guides on the German tax certificate and VAT. I have trawled through and gathered information as well as being in contact with Amazon Germanys executive sellers team. I have pasted their mail below. My question is, it seems we have to get this tax certificate to trade again and, one of the links suggest using a company KPMG as well as some other links. The choices seem overwhelming and, we could really do with your advice as to whihc company/companies you would recommend who assist from start to finish with a limited company such as ours based in the UK since 1964. To get a VAT number, to get a German tax certificate and to file the VAT seem the three things we need? I hoep you can offer some guidance and thank you in advance!

    Best wishes,

  10. Hi Andrew
    Despite having in good time made the declaration that I do not fulfill any of the three criteria for needing a German Tax Certificate, Amazon have still blocked my sales channel in Germany . Every time I contact them about it they just quote the three criteria and then when I challenge that they transfer the case, after which I hear nothing.
    My question is, now that we’re leaving the EU 🙁 at the end of January will I need the Certificate anyway from that point.

    1. Andrew Minalto

      Hi Yvonne,

      Thanks for your comment.

      Yes, I believe they have changed the rules of this recently as you’re not the first person who says that their Amazon.de account has been deactivated. As far as I understand, Amazon now asks all sellers to register for the tax number in Germany to be able to sell there. It’s hard for me to tell as I already have a VAT number there.

      Maybe take this as an opportunity to expand your business with the PAN-EU program? Amazon is currently running a special promotion where they cover 100% of your VAt registration costs and returns costs for one full year. I have done a post about this with more details here:


      Hope this helps!


      1. Martin

        Hi Andrew, Thank you for taking the time to show so many guides on the German tax certificate and VAT. I have trawled through and gathered information as well as being in contact with Amazon Germanys executive sellers team. I have pasted their mail below. My question is, it seems we have to get this tax certificate to trade again and, one of the links suggest using a company KPMG as well as some other links. The choices seem overwhelming and, we could really do with your advice as to whihc company/companies you would recommend who assist from start to finish with a limited company such as ours based in the UK since 1964. To get a VAT number, to get a German tax certificate and to file the VAT seem the three things we need? I hoep you can offer some guidance and thank you in advance!

        Best wishes,

      2. Andrew Minalto

        Hi Martin,

        Thanks for your comment.

        Yes, initially Amazon allowed sellers to opt-out and still continue selling in Germany, but now it seems that they ask for registration in Germany for ALL sellers who want to sell on Amazon.de I already have German VAT number, so nothing changes for me, but for you – you will have to go through the registration process.

        I outsourced this process (registrations) and monthly returns to this company: https://www.vatglobal.com

        They have been very good, so I can def. recommend you use them too. Even more, for my blog readers, I have arranged a special discount – when you contact them, make sure to mention this coupon code to qualify for a discount: ANDYVAT2020

        Hope this helps Martin & let me know if you have any further questions.


  11. Hi Andrew
    I would like to tell you my story and you may help me.
    I sell to all EU Amazon marketplaces but i am too far from the 100k threshold. Actually couple years ago i sent a box with few items to the German Amazon store. They were sold and since then i didn’t bother. On my account it was ON that i am FBA seller which i removed it the last days. Amazon informed me that i have to register for German VAT so they sent me about month ago a questionnaire to fill in. I started to fill it in but i got stuck as first question is ‘are you sole trader or company’. I write ‘sole’. Second question ‘what company have you got?’ I can’t skip it!!! Further down is asking shareholders details but i can’t skip it. If i do not complete the form it doesn’t let me upload it to them. I opened a case for help but since the 4th of October no answer and the status is marked as ‘transferred’ probably to the correct team. Any idea? I am afraid that i will never get help and soon or late i will be suspended. Are you aware about this questionnaire? I want to proceed but i got stuck because that.

    1. Andrew Minalto

      Hi Notis,

      Thanks for your comment.

      If you’re a registered Sole Trader, your company name will be your actual full name.

      So the “company” name should be your full name. At least that’s how I see it.


      1. Hello again Andrew
        From the drop down menu I have the choice of:
        Public Limited Company
        Limited Company
        Limited Partnership
        UnLimited Partnership
        Chartered company
        Statutory Company
        Holding company
        How can it be, on the first question I mark SOLE trader but on the second I HAVE TO mark one of the above companies too! I tried to get help through the Amazon forum but it seems none knows this questionnaire. It may be new but it may be something wrong with that.
        If I skip it cannot be completed to uploaded it to Amazon. I asked twice their help but my case is pending as it is ‘transferred’. Any idea?

      2. Andrew Minalto

        That doesn’t sound right, no. If you picked Sole Trader, it shouldn’t offer you this list.

        It could be a glitch in the system, hard to say, but only Amazon will be able to resolve this for you.

        You could try using a different browser though? Sometimes in Safari I get similar glitches, but when switching over to Chrome, it goes away. You could also try clearing the CACHE in your browser.


      3. No it isn’t through the browser. It is a downloaded Excel through my Amazon’s central. Tnanks for your efforts. In case I have news I will let you know in case other people have the same problem. Regards Notis

      4. Andrew Minalto

        Thanks Noties, please do so.


  12. Hi Andrew, thanks for this informative post. I am trying to get VAT registered in Germany but I hear that Germany is also served by fulfilment centres in Poland and the Czech Republic. Does this mean I have to register for VAT in Poland and the Czech Republic as well or there is a way to ask the German FCs not to move my stock to these two countries. Thanks you!

    1. Andrew Minalto

      Hi Daniela,

      Thanks for your comment.

      Yes, you will have to register for VAT in Poland and the Czech Republic too as Amazon uses warehouses in those countries to serve the German market. No, you can’t choose where your stock is going and just register in Germany.


  13. Oriol Font

    Hi Andrew

    What company did you use to register/get your VAT in Germany? took a lot of time?

    thank you!


    1. Andrew Minalto

      Hi Oriol,

      I used VAT Global and it took 4 or 5 months.


  14. Hello
    We are Uk based seller and not registered for Pan Europe but certainly sell through Fba to Germany. But we are way below threshold.
    Now Aamzon is asking us to submit Tax certificate as some customer returns get stored in Germany.
    So can we obtain tax certificate and not register for Vat as we are below threshold?
    And after obtaining for Tax certificate what would be our obligation. Can you please guide us on this.
    Many thanks

    1. Andrew Minalto

      Hi Varsha,

      Thanks for your comment.

      It’s a good question to which I don’t know the answer… IN theory, if goods are stored in Germany, you need to register for VAT there too.

      But I’m not 100% sure how it works in relation to returns.

      You will have to do some research online to find out more. I am VAT registered in Germany.


  15. Peter Reynolds

    How does the Section 3 paragraph 8 thing work? At the moment it’s irrelevant to UK sellers but potentially will be relevant if Britain leaves the EU.

    ABEbooks (a subsidiary of Amazon) says that I don’t have to register if (amongst other things) I:
    “… ship goods directly from outside the EU to customers in Germany and for all these shipments the customer (or the carrier as the agent of the customer) will make any import declarations to German customs authorities, and the customer will be the sole debtor of any import VAT in line with Sec. 3 para. 8 of the German VAT Code.”

    So how do I know whether the buyer or the receiving carrier in Germany will do that or not? What does Sec. 3 para 8 actually say? Is it this? “(8) Gelangt der Gegenstand der Lieferung bei der Beförderung oder Versendung aus dem Drittlandsgebiet in das Inland, gilt der Ort der Lieferung dieses Gegenstands als im Inland gelegen, wenn der Lieferer oder sein Beauftragter Schuldner der Einfuhrumsatzsteuer ist.” For instance if I (here in Britain) as a private individual buy goods from USA the customs authorities assess whether they are of sufficient value for me to need to be charged VAT, and, if they are of a high enough value, they charge me VAT and the carrier in UK charges me a whopping handling charge. Is this going to happen in Germany?

    Or since Section 3 paragraph 8 referes to goods coming from a third country (“(“Drittlandsgebiet”) this seems to imply there are three countries involved, so is it talking about goods that go from outside EU (e.g. post-Brexit Britain) to Germany for onward sale into yet another country? In which case my sales to Germany would not be going on to yet another country so would not be liable.

  16. Hi Andrew – if a company is obliged to register for VAT based on the criteria you mentioned, does it imply that on top of VAT the company will also have to pay all other taxes (on profits etc) based on the german tax system?

    1. Andrew Minalto

      Hi Andrew,

      No, there’s do double taxation. You only pay VAT in Germany on sales to German market.


  17. Well I used VAT Global and wow what alot of paperwork to complete.

    We still need to get the Spanish Forms legalised before we are VAT registered in Spain. Can you recommend a good notary public that is charging a fair price?

    1. Andrew Minalto

      Hi David,

      I’m in the same boat actually – all others are done, but I haven’t yet got all the docs for Spain.

      So can’t really recommend anyone…


  18. Karl Clayton

    We are a U.S.A. based business selling on Amazon EU and only hold stock in Amazon U.K. . We do not exceed the 100,000 Euro threshold per year.

    We have sent over 30 emails, acknowledged the exemption form 8 times and received 10 requests for a German VAT Certificate.

    None of this advice is working so the only action to take is to move stock to Amazon Germany warehouse and start the whole VAT registration process. Amazon will not honor their exemption acknowledgement submissions.

    1. Andrew Minalto

      Hi Karl,

      Do you sell to Amazon.de using UK stock?

      It could be that returns are stored in Germany and that’s why they pressure you to register for VAT?

      Apart from that, you can take off Germany from the country list you sell to from Amazon UK.


      1. How do we check if returns are held in Germany? I have the same situation as Karl.


      2. Andrew Minalto

        Hi Gary,

        You go to Reports – FBA reports and there’s a Daily Inventory report which shows all the units in stock and warehouse locations/country.

        Just run that report and you will see if any units are held in Germany.


  19. Hi Andrew,

    We are a Canadian business that sell on Amazon France, Germany, Italy and Spain. We had are Amazon Germany account suspended for 7 week now.

    -We do not warehouse our inventory in German.
    -We never have sold over the threshold of 100,000.00 EUR.
    -We do not have a German Vat number.

    -I received a German tax declaration from Amazon and have already submitted it.
    -I also submitted an appeal to reactivate my account but did not get a reply.
    -I’ve contacted Amazon customer support at least 10 times but they know nothing.

    Do you have any other suggestions, what more can I do to get my account reinstated?

    Thank you,

    1. Andrew Minalto

      Hi Cherif,

      Thanks for your comment.

      Unfortunately, I don’t have any recommendations apart from keeping contacting them?

      Maybe try searching on Amazon Seller forums – for similar cases and see what people have been doing?


  20. Scott Marshall

    Hi Andrew, as always, an easy to read but indepth coverage of an area that (previously) baffled most of us. Thank you for your insights. Very helpful.

    1. Andrew Minalto

      Thanks Scott.

      Yes, I know that this is basically “old news”, but I wanted to lay out all the information in an easy to understand manner as I receive lots of email from people struggling to understand the whole thing. Good to hear it was an easy read for you Scott as the whole situation is far from easy! 🙂


  21. hi Andrew, good article. However is kinda complicate selling on amazon.de. Is not about VAT, is for the new German law that was introduced in March’19. Is a Tax registration module called F22 that is mandatory to sell in Germany. many account are already suspended whitout this Tax module. German Gov gave extra little time, til october 2019 to send this module on your amazon account. Now, without this module is impossible sell on .de market place.
    the bad news is the fact that you cannot obtain the F22 online. yes the apply is on the German gov website, but at the moment is ONLY shipped via a physical address in Germany. They won’t ship on the rest of europe. So for sure we gonna see some 3rd part service in germany that gonna apply for you, but is not quickly. To see your Tax Module F22, on your postbox (or some of your german friend that scan in PDF for you) you need to wait 4 months..
    so German VAT is no more sufficient.
    There are tons of post, message, for example here on amazon europe seller central forum (https://sellercentral-europe.amazon.com/forums/t/anyone-registered-for-the-new-german-tax-certificate-now-in-jan-2019/183554/170) Many people justremove German marketplace to their sales business etc… at the moment is no so easy…..

    1. Andrew Minalto

      Hi Tiziano,

      You’re talking about the situation when you’re VAt registered in Germany.

      This article is for people who want to sell to German customers WITHOUT getting VAT registered.

      These are two totally different situations.


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