VAT Compliance · ViDA · 2028

Do You Still Need a German VAT Registration After 2028?

Published: July 29, 2026 · 10 min read

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Key Takeaways

Information verified by Vaytax as of July 2026. Sources: Council Directive amending Directive 2006/112/EC on VAT rules for the digital age (political agreement 5 November 2024, formally adopted March 2025); Articles 14a, 17a, 194, 218, 222, 226, 262, 263, 369b and 369xa ff. of the EU VAT Directive; UStG §3, §6b, §13b, §14, §18j.

Every few weeks a seller asks us some version of the same question: “I have heard the EU is scrapping local VAT registrations, so should I wait?” The short answer is no, do not wait. The longer answer is more useful, because the reform is real, it is dated, and it will genuinely change what some sellers need. This guide sets out what actually changes on 1 July 2028, which obligations survive it, and what replaces the ones that disappear.

1. The short answer

From 1 July 2028, a foreign business will often be able to avoid a local VAT registration for supplies of goods. It will not be able to avoid one entirely if it does any of the five things listed in section 3. And a registration is only one of your obligations: the reporting does not go away, it moves.

Two mechanisms do the work. Either the customer becomes liable for the VAT under a reverse charge, or you report the transaction through an expanded One-Stop-Shop instead of a local return. Where neither fits, you still register locally, exactly as today.

2. What actually changes on 1 July 2028

The foreign reverse charge becomes mandatory

Today, Article 194 of the EU VAT Directive lets member states shift the VAT liability to the customer when the supplier is established abroad. It is an option, and every country has used it differently. Germany applies it to work supplies and services under §13b UStG but not to plain supplies of goods. Some countries apply it more widely, some restrict it to customers with a local VAT ID, and at least one has never implemented it at all. That patchwork is precisely why the current rule fails to prevent registrations.

From 1 July 2028 the core of Article 194 becomes mandatory for all member states. The liability shifts to the customer whenever both of the following are true:

Where that applies, it covers local supplies of goods (including a non-moving supply in a chain transaction and a local sale from a warehouse), work and installation supplies, and all types of services.

Note the first condition carefully. The mandatory reverse charge only applies if you are not registered in that country. Being registered can therefore take you out of it. Member states keep an option to extend the reverse charge to suppliers who are locally registered as well, so a country-by-country check will still be necessary after 2028.

One-Stop-Shop is extended to local supplies

Today the One-Stop-Shop covers intra-community distance sales and the deemed supplies of marketplaces. It does not cover a local sale from a warehouse inside the country, which is exactly the transaction that forces a foreign seller with German stock to register in Germany.

From 1 July 2028 the scheme is widened to include:

For these supplies of goods it does not matter whether your customer is a business or a consumer. That is a significant change from today.

Services are the exception, and it is an important one. For services, the One-Stop-Shop remains limited to non-business customers. A service that is taxable in another member state and supplied to a business can therefore still create a registration obligation there. The old distinction between a supply of goods and a supply of services keeps mattering after 2028, and it decides whether you register or not.

A new One-Stop-Shop for moving your own stock

Moving your own goods from one EU country to another (a transfer, or innergemeinschaftliche Verbringung) is the transaction that forces Pan-EU sellers to register everywhere their inventory sits. From 1 July 2028 there is a dedicated One-Stop-Shop scheme for it, and the matching intra-community acquisition is exempt and explicitly creates no registration obligation.

The practical detail matters more than the headline:

Call-off stock simplification is abolished

Because the transfer scheme replaces it, the call-off stock simplification (Konsignationslagerregelung, §6b UStG) is withdrawn. Goods can last be placed into call-off stock under the simplification on 30 June 2028, and because of the twelve-month rule the last withdrawals under it fall on 30 June 2029. If you run a consignment arrangement with a German customer, that is a real transition to plan, not a paperwork detail.

3. The five cases where you still need a German registration

This is the part that gets lost in the “single VAT registration” headlines. Even after 1 July 2028, a foreign business must still register for VAT locally in these situations:

SituationWhy the One-Stop-Shop does not solve it
Intra-community acquisitions from a third party Buying goods that arrive in Germany from another EU supplier is an acquisition you must declare. It is outside the scheme.
Acquisitions from your own transfers, if you do not use the new scheme The exemption depends on actually being in the transfer scheme. Opt out, or miss the application deadline, and the ordinary acquisition rules apply.
Intra-community supplies or exports out of Germany Shipping from German stock to a business in another EU country, or to a country outside the EU, is not covered. This applies in both two-party and chain transactions.
Local supplies to a business customer that is not registered The mandatory reverse charge requires the customer to be VAT-registered in that country. If they are not, and the member state does not provide a reverse charge anyway, you are liable.
Anything involving a fixed establishment A fixed establishment (feste Niederlassung) in Germany takes you out of the “non-established supplier” rules altogether.

Read that list against your own flows rather than against the headline. A seller whose German stock only ever serves German consumers, and whose inventory movements all run through the transfer scheme, has a genuine case for deregistering in 2028. A seller who also ships from German stock to business customers elsewhere in the EU, or who imports goods into Germany from outside the EU and wants the import VAT back, does not.

Import VAT is the quiet one. If your goods enter the EU through Germany, the import VAT you pay at the border is recovered through a German VAT return. Nothing in ViDA changes that. Sellers importing into Germany should assume their registration stays.

4. The 2027 change most sellers have not noticed

A year before the registration changes, on 1 January 2027, the marketplace deemed-supplier rule widens. Today, when a business established outside the EU sells goods that are already inside the EU through an online marketplace, the marketplace is treated as buying and reselling the goods, but only where the customer is a consumer or a similar non-taxable person.

From 2027 that fiction also covers sales to ordinary VAT-registered business customers. The consequence is practical and it catches buyers, not just sellers:

If you buy for your business through a marketplace, buy through a business account. Marketplaces are allowed to presume that a buyer who has not identified as a business is a consumer. Order through a private account and you will get a consumer invoice, which does not support an input VAT deduction. Sellers should expect their business buyers to start asking about this in 2027.

Also from 1 January 2027, the non-Union One-Stop-Shop scheme stops being limited to services supplied to private individuals resident in the EU, and covers services to all non-taxable persons.

5. What is coming in 2030, and why it affects a decision you make now

From 1 July 2030, electronic invoicing becomes the default for B2B transactions across the EU, the recipient’s consent is no longer required, and the EU Sales List (Zusammenfassende Meldung, ZM) is replaced by transaction-level digital reporting.

The timings are tight enough to be an operational problem rather than a compliance footnote:

Three new mandatory invoice fields arrive with it: the supplier’s bank account details, the original invoice number when you issue a correction, and an explicit “triangular transaction” reference where one applies. The bank account requirement exists so tax authorities can match the flow of money to the flow of goods.

The trap for anyone choosing an invoicing format right now. Germany’s national e-invoicing mandate started on 1 January 2025 and permits certain interoperable formats domestically. Those national formats are not valid for cross-border transactions from 2030, which will require the European standard (EN 16931, the CEN format). Hybrid formats that embed structured data in a readable document, such as ZUGFeRD from version 2.0.1 onward (excluding the MINIMUM and BASIC-WL profiles), do qualify. If you are picking a format today, pick one that is already standard-compliant, or you will implement it twice.

6. The full timeline

DateWhat lands
1 Jan 2027 Marketplace deemed-supplier rule extended to B2B sales by non-EU sellers. Non-Union One-Stop-Shop widened to all non-taxable customers. One-Stop-Shop covers gas, electricity, heat and cold.
1 Jul 2028 Mandatory foreign reverse charge. One-Stop-Shop extended to local supplies, installed goods and on-board supplies. New One-Stop-Shop for own-stock transfers. Call-off stock simplification closes to new storage. Platform rules extended to short-term accommodation and road passenger transport (member states may defer this part to 1 January 2030).
30 Jun 2029 Last withdrawals possible under the old call-off stock simplification.
1 Jul 2030 Electronic invoicing becomes the default for B2B. EU Sales List replaced by transaction-level digital reporting. Ten-day invoicing and five-day recipient reporting deadlines. New mandatory invoice fields.

7. What to do, and when

One caveat worth stating plainly: Germany has not yet published the national legislation implementing the 2028 changes into the UStG, and member states retain options in several places, including whether to extend the reverse charge to locally registered suppliers. The direction and the dates are settled. Some of the national detail is not.

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Frequently Asked Questions

Does ViDA abolish German VAT registration for foreign sellers?

No. From 1 July 2028 the One-Stop-Shop is extended to local supplies of goods and the foreign reverse charge becomes mandatory, which together remove the need for a local registration in many goods scenarios. But registration is still required for intra-community acquisitions from third parties, for intra-community supplies and exports out of Germany, for local supplies to a business customer that is not itself VAT-registered, for own-stock transfers if you do not use the new transfer One-Stop-Shop, and for any transaction involving a fixed establishment in Germany.

Can an Amazon FBA seller deregister in Germany from July 2028?

Sometimes, not automatically. A seller whose German stock only serves B2C sales, and whose stock movements all go through the new transfer One-Stop-Shop, may be able to. A seller who also ships from German stock to business customers in other EU countries, or who imports goods into Germany from outside the EU, still needs a German VAT registration, because intra-community supplies, exports and import VAT recovery are all outside the One-Stop-Shop.

What happens to call-off stock (Konsignationslager) under ViDA?

The call-off stock simplification is abolished, because the new One-Stop-Shop for own-stock transfers replaces it. Goods can last be placed into call-off stock under the simplification on 30 June 2028, and because of the twelve-month rule the last withdrawals under it are on 30 June 2029.

Is the new One-Stop-Shop for stock transfers monthly?

Yes. The new scheme for own-stock transfers requires a monthly return, due on the last day of the following month, and a nil return must be filed for months with no transfers. It is a separate registration and it is only available if you have full input VAT deduction in the destination country.

When do the ViDA e-invoicing and reporting rules start?

1 July 2030. From that date electronic invoices become the default for B2B transactions, recipient consent is no longer required, and the EU Sales List is replaced by transaction-level digital reporting. Invoices for reportable transactions must be issued within ten days of the supply and reported on the day of issue at the latest by day ten, and the recipient reports within five days of receiving the invoice.

Should I delay my German VAT registration until 2028?

No. The rules that apply to you are the rules in force when the transaction happens. If you store goods in Germany or make taxable supplies there today, the obligation exists today, and an unfiled period does not become compliant because a future reform might have covered it. Registering late means back-filing the missed returns and exposure to late-filing penalties and estimated assessments (Schätzbescheide).

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