Got a German VAT Audit Notice (Umsatzsteuer-Sonderprüfung)? What Amazon Sellers Should Do

An audit notice from the German Finanzamt (German tax office) lands harder than a routine reminder. It is formal, it names a person who will examine your books, and it usually arrives after Amazon has already reported your sales data. The instinct is either to panic or to freeze. Neither helps. A VAT audit is a defined procedure with defined steps, and foreign sellers who respond properly almost always end up with an assessment that reflects their real numbers, not the worst-case estimate.

This guide assumes you have already received the notice. If you are reading ahead of time to understand the risk, start with our pillar guide on Amazon VAT audits in Germany instead.

How do I recognise a German VAT audit notice?

A German VAT audit notice is a letter headed Prüfungsanordnung (audit order), issued under §196 Abgabenordnung (AO), that announces an audit of your VAT. Look for these markers, which appear in predictable places even if you do not read the German body:

• The word Prüfungsanordnung near the top or in the subject line. This is the single most reliable signal that the letter is an audit notice rather than a bill or a reminder.
• The audit scope. The notice names the tax type (Umsatzsteuer, VAT) and the specific periods or years under examination, for example 2022 to 2024.
• The type of audit. An Umsatzsteuer-Sonderprüfung (VAT special audit) is narrow and focuses only on VAT. A Betriebsprüfung (general field audit, §193 AO) is broader and can cover several tax types at once. Foreign e-commerce sellers most often receive the VAT special audit.
• An appointed auditor (Prüfer) and a proposed start date. The notice usually names the official who will conduct the audit and proposes when it will begin.
• The legal basis, written as § 196 AO or with references to §§ 193 ff. AO and the audit ordinance (Betriebsprüfungsordnung, BpO).

This is different from a Schätzbescheid (estimated assessment), which is a tax bill the Finanzamt has already calculated for you. An audit notice announces that someone will examine your records; a Schätzbescheid is the number that can follow if you do not cooperate. If you are unsure which one you are holding, our guide on identifying a Finanzamt letter without reading German walks through every type.

What does the Finanzamt typically request in a VAT audit?

In a VAT audit the Finanzamt asks for the records that let the auditor reconstruct your German-taxable turnover from scratch. For a foreign Amazon seller, the request usually covers the following.

The reason the warehouse data matters so much: under the marketplace rules in §22f and §25e UStG, the marketplace already reports your transaction data to the German authorities. The auditor is reconciling what the marketplace reported against what you declared. Gaps between the two are what the audit exists to resolve.

What are the deadlines, and what happens if I miss them?

There is no single appeal deadline on an audit notice the way there is on a Schätzbescheid; instead there are several operative dates, and missing them is what creates real exposure.

• The proposed start date. The notice proposes when the audit begins. You can request a reasonable postponement (Verlegung) under §197 AO if you have good cause, for example to give your advisor time to prepare the records. The request has to be made promptly and with a reason; it is not an automatic right.
• The record-production dates. Once the audit is under way, the auditor sets dates by which you must hand over the requested documents. These are the deadlines that bite.
• The one-month formal window. A Prüfungsanordnung is technically an administrative act, so a formal Einspruch (objection) against the audit itself is possible within one month under §§347 ff. AO. In practice you rarely contest the audit; you contest the result. The month matters mainly if the audit scope or jurisdiction is plainly wrong.

If you miss the record-production deadlines or refuse to cooperate, the Finanzamt does not drop the case. It estimates your VAT under §162 AO, and that estimate is deliberately conservative, which for the taxpayer means high. It can add a surcharge for non-cooperation, and sustained obstruction can turn a routine audit into a fraud investigation (Steuerfahndung). Because German tax debts are enforceable across the EU under the mutual-assistance rules, and because any inventory sitting in a German fulfilment centre is directly reachable, staying silent does not protect a foreign company. It removes your chance to shape the outcome.

Why does responding through a licensed German tax advisor matter?

Responding through a licensed German tax advisor matters because the audit is conducted in German, on German procedural rules, and the way your data is framed materially changes the result. Three concrete reasons.

• Language and service of documents. Correspondence with the Finanzamt must be in German under §87 AO, and a foreign company without a German address needs a Zustellungsbevollmächtigter (authorised agent for service) under §123 AO so the audit office can validly deliver decisions. A licensed German tax advisor fills both roles.
• Framing the marketplace data correctly. Amazon's reported figures are gross and include shipments to other EU countries and B2B reverse-charge sales that are not German-taxable. An advisor presents your transaction-level data so the auditor taxes only the genuinely German-taxable portion, rather than the inflated gross number.
• Managing the close-out. The audit ends with a closing meeting (Schlussbesprechung) where the findings are discussed before the assessment is finalised. Having a German Steuerberater at that table, who can argue the legal and factual points in real time, is where the final figure is often settled.

You do not need a fiscal representative in Germany. Germany lets non-EU companies be represented directly by a licensed Steuerberater, without that extra layer. See our explainer on fiscal representation in Germany for the distinction.

The step-by-step process and rough timeline

A VAT audit follows a predictable sequence. Here is what happens from the notice landing to the case closing.

1. The notice arrives (day 0). The Prüfungsanordnung names the scope, the auditor, and a proposed start date, usually a few weeks out. Note the date on the letter, not the date you opened it.
2. Engage representation and confirm or postpone the start (first days). A licensed German tax advisor reviews the notice, confirms the authorised agent for service, and either accepts the start date or requests a reasonable postponement under §197 AO to prepare.
3. Assemble the records (the preparation window). You and your advisor pull the transaction data, invoices, registration evidence, and warehouse stock-movement reports the auditor will request, and reconcile them against the marketplace's reported figures so there are no surprises.
4. The audit runs (a few weeks to a few months). The examination is often handled remotely or at the advisor's office rather than at your premises. The auditor reviews records, raises queries, and your advisor answers them. Duration depends on how many years are covered and how clean the data is.
5. Closing meeting (Schlussbesprechung). The auditor presents the findings. Disputed points are argued here before anything is finalised. This is the main opportunity to correct an overstated figure.
6. Written report and amended assessment. The auditor issues a report (Prüfungsbericht); any correction to your VAT arrives as an amended assessment, which itself carries a fresh one-month Einspruch window if you still disagree.

Rough end-to-end timeline for a focused VAT special audit on a single seller: a few weeks to a few months from the start date to the closing report, with most of the variation driven by the number of years under audit and how quickly records are produced.

Common mistakes foreign sellers make

Frequently asked questions

How do I know if the letter I received is a German VAT audit notice?

Look for the word Prüfungsanordnung (audit order) in the subject line or top of the letter, plus a citation to §196 AO. It will name the tax type and periods under audit (Umsatzsteuer plus the years), the appointed auditor, a proposed start date, and the legal basis. A Prüfungsanordnung announcing an Umsatzsteuer-Sonderprüfung (VAT special audit) or a Betriebsprüfung (general field audit) is the audit notice. It is different from a Schätzbescheid, which is an estimated tax bill rather than an announcement of an audit.

What documents will the German Finanzamt ask for in a VAT audit?

The auditor typically requests transaction-level sales records for the periods under audit, outgoing and incoming invoices, your German VAT registration evidence (Steuernummer and the Fragebogen confirmation), warehouse and stock-movement data showing when inventory entered or left German fulfilment centres, marketplace settlement reports, and proof of any intra-EU or export movements you treated as zero-rated. For Amazon FBA sellers, the stock-movement and fulfilment data is usually the centre of the audit.

What is the deadline to respond to a German VAT audit notice?

A Prüfungsanordnung is itself an appealable administrative act with a one-month Einspruch window under §§347 ff. AO, but in practice you do not appeal the audit itself. The operative deadlines are the proposed audit start date (you can request a reasonable postponement under §197 AO with good cause) and the dates the auditor sets for handing over records. Missing those deadlines lets the Finanzamt estimate your VAT under §162 AO, which usually produces a much higher figure than your real numbers.

What happens if I ignore a German VAT audit notice?

Ignoring the notice does not cancel the audit. The Finanzamt can proceed without your cooperation and estimate the tax owed under §162 AO, which is deliberately conservative and almost always overstates real liability. It can add a late or non-cooperation surcharge, and persistent non-cooperation can escalate a routine audit into a tax-fraud review (Steuerfahndung). Because German tax debts are enforceable across the EU and any inventory in a German warehouse is reachable, a foreign company cannot avoid exposure by staying silent.

Why should a foreign Amazon seller respond through a licensed German tax advisor?

Correspondence with the Finanzamt must be in German under §87 AO, and a foreign company without a German address needs a Zustellungsbevollmächtigter (authorised agent for service) under §123 AO so the audit office can deliver decisions. A licensed German tax advisor fills both roles, deals directly with the auditor, frames your Amazon settlement data correctly so the auditor does not tax EU-cross-border or B2B reverse-charge sales as German turnover, and represents you through to the close-out so the assessment reflects your real liability.

How long does a German VAT audit take and what does it cost?

A focused Umsatzsteuer-Sonderprüfung on a single seller usually runs a few weeks to a few months from the start date to the closing report, depending on how many years are covered and how quickly records are produced. The audit closes with a final meeting (Schlussbesprechung) and a written report; any correction arrives as an amended assessment. The cost of professional representation is quoted per case because it depends on the years under audit, the volume of transactions, and whether returns need reconstructing. Routine ongoing compliance with Vaytax is €79 per month, or €1,199 per year all-in if you still need German VAT registration (registration included).