What is the reverse charge procedure?

The reverse charge procedure (reversal of tax liability) flips the standard VAT logic. Instead of the seller, the buyer is liable for the VAT to the tax office. The legal basis in Germany is § 13b of the German VAT Act (UStG). In concrete terms, this means: The seller issues a net invoice without VAT. The buyer (a business) calculates the tax themselves, reports it, and can simultaneously deduct it as input tax. In practice, it is often just an accounting process for both sides—but only if documented correctly. For Amazon sellers, this procedure is particularly relevant for incoming invoices (services) from foreign Amazon entities. For your outgoing invoices (goods sales) to business customers in other EU countries, the legally separate principle of intra-Community supply applies instead.

Where does the reverse charge procedure still apply for Amazon sellers?

Even after the changes made by Amazon, the reverse charge procedure remains relevant for Amazon merchants in two key scenarios: B2B sales to other EU countries: If you sell goods via Amazon to a company based in another EU country, this constitutes an intra-Community supply. You issue a net invoice—the buyer reports the tax in their country. Requirements you must strictly fulfill: The buyer's VAT ID must be valid and verified. The invoice must contain the mandatory notice regarding tax exemption, for example: "tax-free intra-Community supply". Note: A reference to the tax liability of the recipient (reverse charge) is legally inadmissible here, as this is a supply of goods and not a service. The turnover must be reported in the EC Sales List (ZM). If any of these points are missing, you are personally liable for the tax—even retroactively. Incoming invoices from foreign Amazon entities (remaining balance): For services that Amazon still bills via a non-German entity (certain advertising services, international services), you will continue to receive net invoices. You must calculate the German VAT on these yourself and report it in your VAT return.

Amazon Reverse Charge for Sellers: What Still Applies – and What Changed in 2024

Q: Does the reverse charge procedure still apply to Amazon?

Yes—but with one important limitation. Since August 2024, Amazon has been issuing most fees with 19% VAT (via German branches). The reverse charge procedure continues to apply to service invoices from foreign Amazon entities (e.g., certain advertising services). For B2B goods sales to other EU countries, however, the principle of intra-Community supply applies.

Amazon restructured its billing in August 2024: most seller fees now come with local VAT instead of reverse charge. But the mechanism still applies to EU B2B sales and certain Amazon invoices. This guide explains what changed, what remains, and how to stay compliant without manual effort.

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Amazon Reverse Charge for Sellers: What Still Applies – and What Changed in 2024

Das Wichtigste in Kürze

Since August 2024 Amazon has stopped processing most fees for German sellers via the reverse charge mechanism, instead applying 19% VAT (via Amazon Germany).
The reverse charge mechanism (Section 13b UStG) still applies to service invoices from Amazon entities billing from abroad (e.g., certain foreign advertising budgets). For physical B2B goods sold within the EU, however, the legally distinct principle of tax-exempt intra-Community supply applies.
Incorrectly recording or missing reverse charge invoices risks tax arrears and late payment penalties during audits.
Correct VAT ID verification remains mandatory. While the Federal Fiscal Court ruling of January 31, 2024 (V R 20/21) clarified that a valid recipient VAT ID is not strictly required for the reverse charge mechanism on cross-border B2B services (Section 13b UStG) provided the recipient's business status can be proven otherwise.Caution: This relief explicitly does notapply to physical B2B trade (intra-Community supplies). Here, a valid and verified customer VAT ID has been a mandatory substantive requirement for tax exemption since 2020. Without a valid number, you immediately lose the tax exemption and become personally liable for the VAT.
Amainvoice automates reverse charge detection, VAT ID verification, and DATEV exports—ensuring no entry slips through the cracks.

What is the reverse charge mechanism?

The reverse charge mechanism reverses the standard VAT logic. Instead of the seller, the buyer is responsible for reporting and paying the VAT to the tax authorities. The legal basis in Germany is Section 13b of the German VAT Act (UStG).

In practical terms, this means:

The seller issues a net invoice without VAT.
The buyer (a business) calculates the tax themselves, reports it, and can simultaneously deduct it as input tax.
In practice, this is often just a bookkeeping entry for both parties—but only if it is documented correctly.

For Amazon sellers, this procedure is particularly relevant for incoming invoices (services) from foreign Amazon entities. For your outgoing invoices (sales of goods) to business customers in other EU countries, the legally distinct principle of intra-Community supplyapplies instead.

The change as of August 2024: What has changed for Amazon sellers?

For a long time, Amazon fees (FBA, Marketplace, advertising) were billed through the Luxembourg branch Amazon Services Europe S.à r.l. . Sellers received net invoices and had to report the German VAT themselves using the reverse-charge procedure.

As of August 1, 2024:

Amazon now bills most services for sellers based in Germany, Spain, France, Italy, Sweden, Poland, the Netherlands, Belgium, and the United Kingdom through local branches onwards. For Germany, this means that invoices for most sales and fulfillment fees will now come directly from Amazon EU S.à r.l., German Branch – with domestic VAT (19%) shown.

What this means for your bookkeeping:

You will receive gross invoices with VAT shown – no more reverse charge for these items.
The VAT is deducted directly from your payout – this impacts your cash flow, especially if you file quarterly VAT returns.
You record these invoices as standard input tax (booking code 401, 19%) – no longer using the § 13b code.

⚠️ Attention: Amazon is rolling out this change service by service. It is possible that you may continue to receive net invoices from foreign Amazon entities for certain services (e.g., specific advertising formats or special services). Check every invoice.

Amainvoice automatically detectswhich Amazon fees include 19% VAT and which continue to be processed via the reverse charge procedure – and books them correctly. This prevents errors that are frequently flagged during tax audits. → Try it out for free

Where does the reverse charge procedure still apply to Amazon sellers?

Even after the changes made by Amazon, the reverse charge procedure remains relevant for Amazon sellers in two key scenarios:

B2B sales to other EU countries

If you sell goods via Amazon to a company based in another EU country, this constitutes an intra-Community supply. You issue a net invoice – the buyer reports the tax in their country.

Requirements you must strictly fulfill:

The buyer's VAT ID must be valid and verified.
The invoice must include the mandatory reference to the tax exemption, for example: "tax-exempt intra-Community supply" (or in English: "intra-Community supply"). Note: A reference to the reverse charge mechanism is legally impermissible here, as this concerns a supply of goods rather than a service.
The turnover must be reported in the EC Sales List (ESL) .

If any of these points are missing, you are personally liable for the tax – including retroactively.

Incoming invoices from foreign Amazon entities (residual value)

For services that Amazon still bills through a non-German entity (certain advertising services, international services), you will continue to receive net invoices. You must calculate the German VAT yourself and report it in your advance VAT return.

Practical example: Correctly processing a B2B sale to Austria

You sell a product to an Austrian company via Amazon FBA (invoice amount: €200).

Here is the correct process:

The buyer provides their Austrian VAT ID to Amazon.
Amainvoice automatically verifies the validity of the number via a live check.
Amainvoice generates the invoice for €200 net – excluding VAT.
The invoice automatically includes the legally required notice regarding the tax-exempt intra-Community supply in the correct local language.
The Austrian company reports the local VAT to its tax office.
Amainvoice automatically prepares the revenue for the EC Sales List.

For comparison: When selling to a private individual in Austria, you charge Austrian VAT and remit it via the One-Stop-Shop (OSS) procedure. Reverse charge only applies to B2B.

Amainvoice automates what is nearly impossible to handle manually

With high sales volumes, it is impossible to check every transaction manually. Amainvoice handles the entire process chain – for both scenarios:

For your outgoing invoices (B2B sales):

Automatic live VAT ID check: Amainvoice verifies the validity of the ID at the time of purchase. A net invoice is only generated if the result is positive.
Legally compliant mandatory notices: The correct notice regarding the tax-exempt intra-Community supply is automatically inserted in the correct language – with no manual effort required.
Automatic EC Sales List preparation: All reportable B2B sales are correctly prepared for the EC Sales List.

For your incoming invoices (Amazon fees):

Intelligent fee classification: Amainvoice automatically detects which Amazon invoices from August 2024 onwards are subject to 19% VAT and which are still processed via reverse charge.
Accurate DATEV export: Your tax advisor receives all entries with the correct codes – no follow-up questions, no errors.

→ Go to accounting analysis for sellers | Try Amainvoice now | View pricing

What the 2024 Federal Fiscal Court ruling means for sellers

A ruling by the Federal Fiscal Court (BFH) on January 31, 2024 (V R 20/21) has clarified: A valid VAT ID is not strictly required for the transfer of tax liability under Section 13b of the German VAT Act (UStG). The tax liability lies with the recipient of the service – regardless of whether a correct number is provided.

What this means in practice: You cannot hide behind a missing or invalid VAT ID to avoid reverse charge obligations. Conversely, you are also liable even if the seller has not provided a number. Documentation remains crucial – those who keep clean records are on the safe side during tax audits.

Important note: This BFH decision regarding relief in the absence of a VAT ID applies exclusively to services (reverse charge under Section 13b UStG). For physical B2B goods traffic (intra-Community supply), a valid and verified VAT ID of the recipient remains a mandatory substantive requirements for tax exemption. Without a valid number, you are personally liable for VAT!

Further articles in the Amainvoice knowledge base

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This article is for general information purposes only and does not constitute tax or legal advice. Please consult a qualified tax advisor regarding your individual situation.

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Frequently asked questions about Amazon Reverse Charge

Does the reverse charge procedure still apply to Amazon?

Yes – but with one important caveat. Since August 2024, Amazon has been issuing most fees with 19% VAT (via German branches). The reverse charge procedure still applies to service invoices from foreign Amazon entities (e.g., certain advertising services). For B2B sales of goods to other EU countries, however, the principle of intra-Community supply applies.

How do I correctly record Amazon fees since August 2024?

Record invoices showing 19% VAT as standard input tax (booking code 401). Continue to record invoices from foreign Amazon entities without VAT using the § 13b code (Reverse Charge). Amainvoice distinguishes between these automatically.

What happens if I record a reverse charge invoice incorrectly?

The tax office will demand the VAT payment—including interest and potential late payment surcharges. With high sales volumes, accounting errors can quickly add up to several thousand euros.

What exactly does Amainvoice do regarding the reverse charge procedure?

Amainvoice automatically verifies the VAT ID of every B2B customer, creates legally compliant net invoices with the correct mandatory legal notices (e.g., regarding intra-Community supply or the reverse charge procedure), correctly classifies incoming Amazon invoices (gross vs. reverse charge), and provides DATEV-compliant exports with the correct booking codes. → Test it now without obligation

Why am I now receiving gross invoices from Amazon instead of net invoices?

Since August 1, 2024, Amazon has been billing its services for German merchants through its local Amazon Germany branch. As a result, VAT is now explicitly stated and withheld by Amazon. You can claim this as input tax.

Do I still need to verify the VAT ID of my B2B customers?

Yes, absolutely. The 2024 Federal Fiscal Court (BFH) ruling only concerns services. For physical B2B goods shipments to other EU countries, a valid and verified VAT ID of the buyer remains a material requirement for tax exemption. Without this verification, you lose the tax exemption retroactively and are personally liable for the VAT.

Do I have to report reverse charge sales separately?

Yes. B2B sales to other EU countries subject to reverse charge must be reported in the EC Sales List (Zusammenfassende Meldung, ZM) to the Federal Central Tax Office.

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