What Brexit changed for German VAT
Before 31 December 2020, UK companies operated in Germany under the same EU VAT rules as any other member state. Distance-selling thresholds, MOSS/OSS access, and intra-EU simplifications all applied. From 1 January 2021, the UK became a third country under EU VAT law — the same status as the US, Canada, or Australia. Concrete consequences:
| Pre-Brexit (before 2021) | Post-Brexit (from 2021) |
|---|---|
| €10,000 EU-wide distance-selling threshold applied | No threshold — any taxable supply triggers registration |
| UK-DE goods treated as intra-EU supplies | Treated as imports — customs declarations, EORI required |
| MOSS/OSS available for cross-border VAT | Excluded from Union OSS — must register locally |
| ZM (EC Sales List) required for intra-EU B2B | No ZM — customs replaces EU reporting |
| Single UK VAT reg often sufficient | Separate German registration required for DE activity |
The core principle: for German VAT purposes, a UK company is now treated exactly like a non-EU company. There is no current UK-EU VAT treaty that restores pre-Brexit simplifications, and no indication that one is coming.
When a UK company must register
Germany has no registration threshold for foreign sellers. The obligation begins the moment you make a taxable supply in Germany. The three most common triggers:
1. Amazon Pan-EU FBA
If you're in Amazon Pan-European FBA, Amazon can (and will) move your inventory into its German fulfilment centres based on demand signals. From the moment your stock crosses the German border, you have a taxable presence in Germany. Registration is mandatory before you sell a single unit from that inventory. Amazon will request your German USt-IdNr. once the inventory is allocated — failing to provide one risks listing suspension.
2. German 3PL or consignment stock
Using a UK-based fulfilment provider's German warehouse, or any German 3PL (Zalando Fulfilment, Otto, independent providers), creates the same obligation. Consignment stock held in Germany — even if not actively selling yet — is a taxable presence.
3. B2C digital/service sales without OSS coverage
UK SaaS and digital service providers selling to German consumers must either use Non-Union OSS or register in Germany. Non-Union OSS covers cross-border B2C digital services from a UK base but does not help with German-located inventory or physical-service scenarios. For enterprise B2B contracts, many German buyers expect a real DE-prefixed USt-IdNr., which requires local registration.
Where UK companies typically do NOT need to register: pure B2B services to German businesses where the reverse charge (§13b UStG) applies throughout, with no German stock or establishment. The German customer accounts for the VAT via their own return. Some service categories are exceptions — check before assuming.
No fiscal representative required — even post-Brexit
This is the single biggest cost trap for UK sellers after Brexit. Some providers imply that because UK companies are now "third country," they need a fiscal representative in Germany. This is not true.
Germany does not require fiscal representation for any third-country business — UK, US, Chinese, Swiss — for standard VAT registration and monthly filing. A licensed Steuerberater acting as your tax agent is sufficient, under §3 StBerG. The distinction:
| Fiscal Representative | Steuerberater (Vaytax) | |
|---|---|---|
| Required for UK companies? | No (§22a UStG narrow exception only) | Yes — this is the standard path |
| Assumes your VAT liability? | Yes — personally liable for your VAT debt | No — you remain the taxpayer |
| Typical annual cost | €1,000–€3,000 extra | Included in €79/month |
For a full breakdown, see our fiscal representation guide. If a provider quotes UK sellers a separate "fiscal rep" fee, ask for the legal basis — there isn't one for standard VAT compliance.
Finanzamt Hannover-Nord: the office that handles UK companies
Germany routes foreign companies to central Finanzämter by country of origin. UK companies — whether based in England, Scotland, Wales, or Northern Ireland — are assigned to Finanzamt Hannover-Nord. This routing is confirmed by the Bundeszentralamt für Steuern (BZSt) and has been stable since 2021.
What Hannover-Nord needs to process a UK-company registration:
- Certificate of Incorporation from Companies House, typically dated within the last 3 months
- HMRC VAT registration certificate (if the company is UK VAT registered)
- Memorandum & Articles of Association showing authorised signatories
- Passport copies of all listed directors
- Completed Fragebogen zur steuerlichen Erfassung in German — see our English walkthrough
- SEPA direct debit mandate for Finanzamt VAT collection
No German bank account is required. UK banks support SEPA transfers, so your existing GBP or EUR business account typically works.
EORI numbers and customs: the post-Brexit extra
Because UK-Germany goods movements are now imports/exports (not intra-EU), you need customs infrastructure that pre-Brexit sellers didn't:
- UK EORI (GB-prefix) — for exporting from the UK. Issued by HMRC, free.
- EU EORI (typically DE-prefix) — for importing into Germany. Issued by the Zollverwaltung, tied to your German tax ID.
- Customs declarations on every shipment. Most 3PLs handle these, but you're the importer of record.
What UK companies do not need post-Brexit: ZM (Zusammenfassende Meldung) and Intrastat — both are intra-EU reporting obligations that no longer apply to UK trade.
Monthly filing: what it actually looks like
Once you have your Steuernummer, the monthly rhythm is simple:
- You: Enter sales figures into the Vaytax dashboard each month (~5 minutes — totals per VAT rate, any B2B supplies, any reverse-charge situations).
- We: Import into DATEV, generate the USt-Voranmeldung, file via ELSTER.
- Finanzamt: Processes the filing, debits your SEPA account for VAT owed.
- You: Get filing confirmation in the dashboard and by email.
First two years: monthly filing is mandatory. From year three: quarterly becomes possible if annual VAT owed is under €7,500. Dauerfristverlängerung (permanent filing extension) gives you an extra month per deadline, in exchange for a refundable 1/11 deposit of prior-year VAT liability.
Annual return (Umsatzsteuer-Jahreserklärung) is filed by 31 July of the following year — or up to 28/29 February of the year after, if filed through a Steuerberater under extension rules.