Amazon reported you. Now a § 25e Schätzbescheid landed.
Amazon transmitted your German marketplace sales to the Finanzamt under § 25e UStG. The Schätzbescheid covers typically 2022 to 2025, calculated from Amazon's gross revenue without your input VAT, OSS deductions, or returns. The bill usually runs 2-5x your real liability. You have 30 days to file an Einspruch, and Amazon may suspend your seller account in parallel.
Amazon's data became the Finanzamt's case file.
This Schätzbescheid is the marketplace-liability variant. The legal mechanism is § 25e UStG, introduced in 2019 and expanded in 2021. It makes marketplace operators (Amazon, eBay, Etsy, Otto, Kaufland) jointly and severally liable for VAT on sales by their sellers, unless the operator can show it verified the seller's VAT compliance. To satisfy that, marketplaces collect German VAT certificates from sellers and transmit per-seller transaction data to the Finanzamt under § 22f UStG.
The Finanzamt then cross-checks Amazon's reported revenue against your UStVA filings. When the gap is material (Amazon shows €200k in marketplace sales for 2024, your filings show €0 or much less), the Finanzamt issues a Schätzbescheid under § 162 AO. The bill is calculated from Amazon's gross figure: (Amazon gross revenue) × 19% VAT, often with no adjustment for the reduced 7% rate on certain goods, no input VAT credit, no OSS-eligible sales removed, no returns netted.
For most foreign Amazon sellers, the typical exposure window is tax years 2022, 2023, 2024, and 2025 (the standard 4-year limitation under § 169 AO). The figures range from €5,000 (small private-label seller with low German market share) to €50,000+ (high-volume FBA seller across multiple ASINs). The Schätzbescheid amount is usually 2-5x what corrected filings would have shown.
30 days for the Einspruch. Amazon may suspend in parallel.
Two parallel deadlines
If you miss the Einspruch deadline: the Schätzbescheid becomes bestandskräftig (legally binding). Retroactive VAT of typically €5k-€50k+ becomes immediately collectible. Interest under § 233a AO continues to accrue from each original VAT due date, often adding another 10-25% over the assessed period. Amazon, having reported your data, will treat the non-compliant status as confirmation and the seller account stays frozen or gets terminated.
If you respond inside the window: we file the Einspruch, request collection suspension (Aussetzung der Vollziehung), file corrected UStVA returns based on your real Amazon VAT Transactions Reports (which include returns, refunds, OSS-eligible sales, and net VAT). Once corrected returns are accepted, we notify Amazon that VAT compliance is restored. Typical seller-account reinstatement is 2-4 weeks after compliance is documented.
Four steps to recover from a § 25e Schätzbescheid.
- File the Einspruch within the 30-day window. A licensed German tax advisor drafts and submits the objection to the issuing Finanzamt, citing §§ 347 ff. AO, naming the Schätzbescheid by Aktenzeichen, and disputing the assessment basis (gross marketplace revenue is the wrong basis for VAT, which is gross-minus-returns-minus-OSS-net of input VAT).
- Request collection suspension (Aussetzung der Vollziehung). Filed alongside the Einspruch under § 361 AO. When granted, the assessed amount cannot be collected (and Amazon will not see active enforcement) until the corrected assessment is issued.
- Reconstruct and file corrected UStVA returns from real Amazon data. We pull your Amazon VAT Transactions Report (VTR), netting returns and refunds, separating OSS-eligible sales from local German B2C, applying input VAT on FBA fees and inventory. Each affected period gets its own corrected UStVA filed via ELSTER.
- Document compliance for Amazon. Once the corrected returns are submitted and the Finanzamt acknowledges receipt, we provide Amazon Seller Performance with the documentation needed to lift the listing freeze. Typical reinstatement: 2-4 weeks. Typical reduction from the original Schätzbescheid amount: 60-80%.
Send us the § 25e Schätzbescheid.
A licensed German tax advisor reviews the assessment, your Amazon VTR if available, and the seller-account risk, then emails back a fixed-price quote within 4 hours (weekdays 9-18 CET). You pay nothing to receive the quote.
Get my quote on the § 25e Schätzbescheid Quote in 4 hours (weekdays 9-18 CET) · No payment to receive itAbout the § 25e Schätzbescheid.
It is an estimated VAT assessment issued by the German Finanzamt based on sales data Amazon reported under § 25e UStG (marketplace operator liability). The figure is calculated from Amazon's gross German marketplace revenue, without your input VAT, OSS-eligible deductions, or returns. The estimate typically runs 2-5x what your actual VAT liability is once corrected returns are filed.
Under § 25e UStG (introduced 2019, expanded 2021), marketplace operators are jointly and severally liable for VAT on sales by their sellers unless they verify the seller is VAT-compliant. Amazon meets this obligation by demanding a German VAT certificate from sellers and reporting transaction data to the Finanzamt. If the Finanzamt cross-checks Amazon's data against your filing record and finds a gap, a Schätzbescheid follows.
Standard statute of limitations under § 169 AO is 4 years from the end of the assessment year. So a Schätzbescheid issued in 2026 can cover tax years 2022, 2023, 2024, and 2025. For cases of negligence (leichtfertige Steuerverkürzung, § 378 AO), the period extends to 5 years. For intentional evasion (Steuerhinterziehung, § 370 AO), 10 years.
Substantially, almost always. Amazon's reported revenue is gross marketplace sales. The actual VAT liability is much lower once you factor in: returns and refunds (typically 5-15%), OSS-eligible cross-border sales (which belong in another EU country's return, not Germany's), input VAT on inventory and fees, and B2B sales subject to reverse charge. Typical reduction from the original Schätzbescheid is 60-80%.
Amazon may freeze listings or suspend the seller account if the Finanzamt notifies them of VAT non-compliance under § 25e UStG. The protection mechanism is fast restoration of compliance: file the corrected returns, pay the agreed amount (or get a payment plan), and we notify Amazon that compliance is restored. Most accounts are reinstated within 2-4 weeks of compliance being restored.
Per § 22f UStG, Amazon must transmit per-seller: total annual marketplace sales (gross), period breakdowns, and the seller's German Steuernummer (or proof of exemption). Amazon does NOT transmit your VAT Transactions Report, returns data, refunds, OSS sales, or input VAT. That is the asymmetry we exploit when filing corrected returns: we reconstruct the real numbers from data Amazon shares with you but does not share with the Finanzamt.