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German seller data and VAT registration obligations for marketplaces

The Federal Ministry of Finance has made marketplaces operating in German jointly and severally liable for their sellers on-platform VAT if they file to comply with new data recordkeeping requirements and checks.

Germany imposed various third-party seller VAT obligations on marketplaces to help tackle an estimated €1million in online fraud in Germany. Germany has gone further in its requirements than the UK in March 2018. France marketplace VAT obligations on reporting and VAT number checks come into force from 1 January 2020.

The EU ecommerce package July 2022 will introduce marketplace deemed supplier obligations, making the marketplace responsible for certain seller transactions.

German seller data and VAT registration obligations for marketplaces

Since 1 January 2019, marketplaces operating in German are obliged to follow the below requirements:

  • Detailed transaction records to help establish potential German VAT obligations
  • A new paper-based F22 VAT certificate from the German tax office verifying the seller is correctly German VAT registered (note, the European Commission has challenged this requirement). This requirement starts 1 March 2019 for non-EU sellers (although now delayed till April); and then 1 October 2019 for EU-based sellers excluding German resident. The paper-based system should be replaced by a digital version from 2022.

Non-EU sellers will need to appoint a German-resident agent to apply for their F22 certificate.

German seller data requirements

Marketplaces must keep the following information on sellers and their platform transactions. Them must be able to provide it on demand to the tax office.

  • The full name and address of the seller;
  • the tax number of the seller, and if appropriate the VAT ID number;
  • the start and end dates for validity of the certificate for the above;
  • the place where dispatch or shipping begins, and the destination; and
  • the date, and quantity of turnover.

Read more about German VAT in our national guide.

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