BDO Indirect Tax News

Germany’s tax authorities issued a circular on 1 July 2025 that sets out additional documents taxpayers may use to be eligible for a VAT-free export of goods from Germany to a country outside the EU. Such exports are zero-rated in Germany provided the taxpayer demonstrates that the goods have been exported to a non-EU country. Failure to produce this evidence could result in a retroactive VAT charge.

Normally, the “Ausgangsvermerk” (export note), a document generated by the customs authorities certifying that goods have left the EU, is used as evidence to support a zero-rated supply. However, there are situations where the export note may not be available (e.g., the system is not working properly, the export was organised by the Department of Foreign Affairs or military transport or stationed troops were used).

The new circular allows the following documents issued by an official body to be recognised as sufficient evidence that goods have left the EU:

• Confirmation by the Department of Foreign Affairs (including diplomatic or consular representations in the country of arrival);
• Confirmation by the military, including their troops stationed in a third country;
• Confirmation by the customs authorities in the country of arrival that the goods were customs cleared and subject to import tax;
• Confirmation by stationed troops (e.g. military transport documents); and
• Settlement note for tax privileges.

Importantly, documents in foreign languages will be accepted only if accompanied by an officially recognised translation, although this may not be necessary where import documents from a third country are issued in English.

Annette Pogodda-Grünwald
Daniel Auer
BDO in Germany