Authorized recipient in Germany: who actually needs one
An authorized recipient (Empfangsbevollmächtigter) is a German-based address the tax office (Finanzamt) can send your tax post to. Under § 123 AO only businesses seated outside Germany, the EU and the EEA can be asked to name one, and only when the Finanzamt actually requests it. An EU or EEA company is not caught by the rule.
Three facts decide this.
Where you are seated: the rule reaches only companies outside Germany, the EU and the EEA, so an Irish or Estonian company is out of scope and a UK, US or Swiss one is in scope. Whether you were asked: the duty is triggered on request, not by registering. What ignoring it costs: letters count as delivered one month after posting, so appeal deadlines can run out before you know a letter exists.
Who must name an authorized recipient in Germany?
Section 123 of the German Fiscal Code (Abgabenordnung, AO) applies to a party with no residence, habitual abode, seat or place of management in Germany, in another EU member state, or in a state to which the European Economic Area agreement applies. That triple exclusion is the part most people miss. A company registered in Ireland, Estonia or the Netherlands is established inside the EU, so § 123 AO cannot be used against it. A company in Iceland, Liechtenstein or Norway sits inside the EEA and is equally outside the provision. A company in the United Kingdom, the United States, China, Switzerland or Turkey is outside both, so the tax office (Finanzamt) may require it to name an authorized recipient (Empfangsbevollmächtigter) inside Germany. Being VAT-registered in Germany does not change where your business is seated: the test looks at your seat, management and residence, not at your German tax number.
| Where your business is seated | Can § 123 AO apply? | What that means in practice |
|---|---|---|
| Germany | No | You are already in the country, so there is no domestic recipient to appoint. |
| Another EU member state (Ireland, Estonia, the Netherlands, and so on) |
No | The provision expressly excludes businesses established in another EU member state. |
| An EEA state (Iceland, Liechtenstein, Norway) |
No | States covered by the EEA agreement are excluded on the same footing as EU states. |
| Outside the EU and the EEA (United Kingdom, United States, China, Switzerland, Turkey) |
Yes, on request | The Finanzamt may require you to name someone in Germany within a reasonable deadline. |
Switzerland is neither an EU nor an EEA state, which is why Swiss companies are in scope even though they sit inside Europe. The United Kingdom left both, so post-Brexit UK companies are in scope too.
When does the tax office actually ask for one?
The obligation is not automatic. § 123 AO says the party must name an authorized recipient auf Verlangen, meaning on request, within a reasonable deadline. Nothing is triggered by registering for German VAT on its own, and there is no advance form for appointing a recipient. What happens in practice is that a letter arrives from the tax office (Finanzamt) asking you to name someone in Germany who can receive tax post, and setting a date by which to reply. Until that letter arrives you have no duty under this provision. Once it arrives, the deadline written in it is the one that matters, and the consequences of ignoring it are set out in the same section of the law. The request is also the point at which the tax office must point out those consequences to you, so read the letter to the end rather than filing it away.
The sentence you are looking for in the German original is „Bitte benennen Sie einen Empfangsbevollmächtigten im Inland.“ If that line is in your letter, this page is about you. Our decoder for common Finanzamt phrases covers the sentences that usually travel with it.
What happens if you ignore the request?
If you are asked and do not name anyone, § 123 AO switches on a deemed-service rule. A document sent to you by post counts as delivered one month after it was handed to the post, and a document transmitted electronically counts as delivered on the fourth day after it was sent. It does not matter whether you opened it, or whether it reached you at all inside that window. The practical damage is deadlines: an assessment (Bescheid) carries an appeal window that starts running from the deemed delivery date, so the right to object can expire before you know the letter exists. There is one exception written into the provision itself: the deemed date does not apply where it is established that the document did not reach the recipient, or reached them at a later time. The tax office must also point out these consequences when it makes the request.
„Ein Beteiligter ohne Wohnsitz oder gewöhnlichen Aufenthalt, Sitz oder Geschäftsleitung im Inland, in einem anderen Mitgliedstaat der Europäischen Union oder in einem Staat, auf den das Abkommen über den Europäischen Wirtschaftsraum anwendbar ist, hat der Finanzbehörde auf Verlangen innerhalb einer angemessenen Frist einen Empfangsbevollmächtigten im Inland zu benennen. Unterlässt er dies, so gilt ein an ihn gerichtetes Schriftstück einen Monat nach der Aufgabe zur Post und ein elektronisch übermitteltes Dokument am vierten Tage nach der Absendung als zugegangen. Dies gilt nicht, wenn feststeht, dass das Schriftstück oder das elektronische Dokument den Empfänger nicht oder zu einem späteren Zeitpunkt erreicht hat. Auf die Rechtsfolgen der Unterlassung ist der Beteiligte hinzuweisen.“
§ 123 AO, Bestellung eines Empfangsbevollmächtigten
- Scope: no residence, habitual abode, seat or place of management in Germany, the EU or the EEA.
- Trigger: on request from the tax authority, within a reasonable deadline.
- Default rule: posted document deemed delivered after one month, electronic document on the fourth day after sending.
- Exception: the deemed date fails where it is established the document never arrived, or arrived later.
- Duty on the authority: it must point out these consequences when it makes the request.
Is an authorized recipient the same as a fiscal representative?
No, and mixing them up is the most common confusion we see. An authorized recipient (Empfangsbevollmächtigter) under § 123 AO is an address: someone in Germany who receives your tax post so that letters from the tax office reach a person who can read them and act in time. The role carries no liability for your VAT and does not make anyone a party to your tax affairs. A fiscal representative (Fiskalvertreter, § 22a UStG) is a different construct entirely: it assumes joint and several liability for a foreign company's German VAT, it files under its own registration, and it exists for narrow customs-related scenarios rather than ordinary VAT registration. Most foreign sellers register for German VAT in their own name and need no fiscal representative at all. If you already hold a German tax number, the open question in front of you is the receiving address, not fiscal representation. We wrote up the fiscal-representative question separately in why most foreign sellers do not need a Fiskalvertreter.
Who can act as your authorized recipient, and can you buy it separately?
Anyone in Germany you authorize can receive your tax post, but the choice matters more than it looks. The letters that arrive are the ones with deadlines attached: assessments (Bescheide), estimated assessments (Schätzbescheide), requests for documents, and hearing notices (Anhörungen). A recipient who cannot read a German assessment and act on it before the objection window closes converts one problem into two. That is why the usual choice is a licensed German tax advisor, who receives the letter, reads it, and tells you what it means and what has to happen next. There is no register of approved recipients and no licence requirement in the provision itself: the appointment is simply a matter of naming the person to the tax office within the deadline you were given. What decides whether it works is not the address but the person behind it, because the deadline on the letter runs whether anyone acts on it or not.
Our position, stated plainly: we act as authorized recipient for our own clients, as part of running their German VAT. We do not sell the role on its own as a mailbox service. Someone who registered elsewhere and only wants a German receiving address is welcome as a filing client, and the role comes with the plan. The reason is simple: a receiving address that is not attached to the person doing your returns is a letterbox, and a letterbox does not answer a Finanzamt deadline.
Practically that means one of two routes. If you already have a German tax number, the filing plan is €89 per month or €990 per year, with no registration fee, and it covers your monthly and annual returns plus the receiving role. If you still need to register in Germany, the all-in plan is €1,299 per year, charged in full at signup, covering the German VAT registration and every filing for the year. Both are listed on our pricing page. You still do your part: you enter your figures or upload your report each period, and we review, prepare and file the return.
If a letter is already sitting on your desk
A request to name an authorized recipient carries a deadline, and so does almost everything the Finanzamt sends after it. If you are holding a German letter you cannot read, our Finanzamt letter reader tells you what it says and what the deadline is, free, before you decide anything.
One address, one team, one set of deadlines.
Vaytax runs German VAT for foreign companies: the registration where you need one, the monthly and annual returns, and the Finanzamt correspondence that goes with them. €1,299 per year all-in including the German registration, or €89 per month if you already have a Steuernummer. A licensed German tax advisor is on record throughout.
Start the registration Licensed German tax advisor · English throughout · No calls requiredAsked about authorized recipients
No. § 123 AO applies only to a party with no residence, habitual abode, seat or place of management in Germany, in another EU member state, or in a state covered by the European Economic Area agreement. An Irish, Estonian or Dutch company is established inside the EU, so the tax office cannot require it to name a domestic authorized recipient under this provision.
No. The duty arises only on request (auf Verlangen). The tax office has to ask you and give you a reasonable deadline to reply. Until that request arrives there is nothing to submit under § 123 AO, and there is no advance form for naming a recipient.
A deemed-service rule switches on. A document sent by post counts as delivered one month after it was handed to the post, and an electronically transmitted document counts as delivered on the fourth day after it was sent, whether or not you read it. Appeal deadlines run from that date. The rule does not apply where it is established that the document did not reach you, or reached you at a later time.
No. An authorized recipient (Empfangsbevollmächtigter) is a German address that receives your tax post and takes on no liability for your VAT. A fiscal representative (Fiskalvertreter, § 22a UStG) assumes joint and several liability for a foreign company's German VAT and applies only in narrow customs scenarios. Most foreign sellers who register in their own name need neither a fiscal representative nor a separate mailbox provider.
Anyone in Germany you authorize to receive tax post on your behalf. In practice it should be someone who can read a German assessment (Bescheid) and act on it before the deadline, which is why a licensed German tax advisor is the usual choice: the letters that arrive are the ones with deadlines attached.
No. We act as authorized recipient for our own clients as part of running their German VAT, and we do not sell the role on its own as a mailbox service. If you already have a German tax number and only need someone in Germany to receive and act on your tax post, the filing plan at €89 per month covers the receiving address together with your monthly and annual returns.
Sources & official references
- § 123 AO: Bestellung eines Empfangsbevollmächtigten
- Abgabenordnung (AO), full text
- § 22a UStG: Fiskalvertretung
General information on German tax procedure, current as of July 2026. Not individual tax advice for your company.