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

TL;DR – Key Takeaways

• Since August 2024, Amazon has stopped using reverse charge for most seller fees in Germany and other EU countries – fees now come with local VAT (19% in Germany).
• The reverse charge mechanism still applies to incoming service invoices from foreign Amazon entities (e.g., certain international ad spend). For your outgoing physical B2B sales of goods to other EU countries, the legally separate principle of exempt intra-Community supplies applies.
• Getting reverse charge wrong – missing a correct VAT number, wrong invoice notation, wrong booking key – can trigger back-taxes and penalties.
• A January 2024 ruling by Germany's Federal Tax Court (BFH) confirmed that a valid VAT ID is not a strict requirement for B2B services under reverse charge, provided business status can be proven otherwise.Warning: This does not apply to B2B goods sales, where a valid VAT ID remains a strict, mandatory requirement for VAT exemption!
• Amainvoice automates VAT ID verification, reverse charge invoicing, and DATEV-compliant exports – so nothing slips through the cracks.

What Reverse Charge Means for Amazon Sellers

Reverse charge (Steuerschuldumkehr in German, legally anchored in § 13b UStG) shifts VAT liability from the seller to the buyer. Instead of charging VAT, collecting it, and remitting it to the tax office, the seller issues a net invoice. The business buyer self-assesses the VAT and typically deducts it simultaneously as input tax – making it largely a bookkeeping transaction.

For Amazon sellers, the reverse charge mechanism is primarily relevant for incoming invoices (services) from foreign Amazon entities. For your outgoing B2B invoices (physical goods sales) to other EU member states, you must apply the legally separate rules for exempt intra-Community supplies.

What Changed in August 2024: The Amazon Billing Restructure

Before August 2024, most Amazon seller fees were billed by Amazon Services Europe S.à r.l. – a Luxembourg-based entity. Because the invoices crossed an EU border, reverse charge applied. Sellers received net invoices, self-assessed German VAT, and reported it in their VAT return.

From 1 August 2024 onwards:

Amazon switched to billing through local entities in the seller's country of residence – including Amazon Deutschland for German sellers. The same change applies to sellers in Spain, France, Italy, Sweden, Poland, the Netherlands, Belgium, and the UK.

The practical impact:

• You now receive gross invoices with VAT explicitly stated (19% in Germany).
• Amazon withholds the VAT directly from your payout – affecting cash flow, especially for sellers on quarterly VAT filing cycles.
• You book these as standard input tax (not § 13b reverse charge).
• The corresponding booking key in DATEV is 401 (19% input tax), not the reverse charge key.

⚠️ Important: Amazon is rolling this out service by service. Some invoices – particularly for certain advertising products or international services – may still come from non-local Amazon entities without VAT. Check every invoice individually.

Amainvoice detects automatically which Amazon invoices carry local VAT and which still fall under reverse charge – and books them correctly. → Start your free trial

Where Reverse Charge Still Applies After August 2024

The restructuring of Amazon's billing model does not eliminate reverse charge from Amazon sellers' day-to-day operations. Two scenarios remain fully active:

EU B2B Sales: Zero-Rated/Exempt Intra-Community Supplies

If you sell products on Amazon to a business customer in another EU member state, the transaction qualifies as an intra-community supply. You issue a net invoice without VAT. The buyer self-assesses VAT in their country.

The requirements you must meet:

• Verify the buyer's EU VAT ID and keep a record of the check.
• Include the mandatory notice on the invoice referring to the VAT exemption, such as: 'exempt intra-Community supply' (or in German: 'steuerfreie innergemeinschaftliche Lieferung'). Note: Do not use the term 'Reverse Charge' or 'Tax liability of the recipient' here, as these terms are reserved for B2B services, and using them on goods invoices can lead to tax authorities revoking your VAT exemption.
• Report the transaction in the Recapitulative Statement (ZM) to the Federal Central Tax Office.

If any of these conditions are not met, you can be held personally liable for the VAT – including retroactively.

Remaining Amazon Invoices from Non-Local Entities

For services that Amazon still bills via foreign entities (certain advertising products, international marketplace services), you will continue to receive net invoices. You must self-assess VAT and report it in your VAT return.

Practical Example: Selling B2B to a Business in Austria

You sell a product via Amazon FBA to an Austrian business. Invoice value: €200 net.

The correct process:

1. The buyer registers their Austrian VAT ID on Amazon.
2. Amainvoice runs an automatic live check to verify the ID is currently valid.
3. Amainvoice generates a €200 net invoice – no VAT charged.
4. The invoice automatically includes the legally required intra-Community supply exemption notice in the appropriate language.
5. The Austrian business self-assesses Austrian VAT and reports it locally.
6. Amainvoice prepares the transaction for your Recapitulative Statement submission.

By contrast, a private consumer in Austria would be charged Austrian VAT, which you remit via the One-Stop-Shop (OSS). Reverse charge is strictly a B2B mechanism.

Amainvoice: Full Automation for Both Sides of the Equation

At scale, manually checking every invoice and VAT ID is not feasible. Amainvoice handles the complete reverse charge workflow – outgoing and incoming:

For outgoing B2B invoices:

• Live VAT ID verification: Amainvoice checks every buyer's VAT ID at the point of sale. Net invoices are only generated upon a positive result.
• Compliant invoice text in the right language: The correct legal notice (referring to either the intra-Community supply or reverse charge, depending on the transaction type) is added automatically, correctly worded for each EU country.")
• Recapitulative Statement preparation: All eligible B2B transactions are automatically flagged and prepared for ZM reporting.

For incoming Amazon invoices:

• Smart fee classification: Amainvoice distinguishes between Amazon invoices with explicit VAT (post-August 2024) and those still subject to reverse charge.
• DATEV-ready export: Your tax advisor receives correctly keyed bookings – reducing back-and-forth and preventing errors in annual accounts.

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The 2024 BFH Ruling and What It Means for Your Compliance

A ruling by Germany's Federal Tax Court (BFH, 31 January 2024, V R 20/21) confirmed that a valid VAT ID is not a formal prerequisite for reverse charge liability to apply. The tax obligation exists regardless of whether the number was provided or valid.

What this means in practice: For B2B services (like digital platform fees), the tax obligation shifts to you even if no valid VAT ID was recorded, as long as your entrepreneurial status is evident.Crucial warning: For physical B2B goods sales, this ruling does not apply. Under the EU 'Quick Fixes' rules, a valid and verified VAT ID of your customer is a material requirement for the tax exemption of goods. If you sell goods to an EU business customer without a validated VAT ID, you are personally liable for the VAT! Thus, thorough docu

Frequently Asked Questions: Amazon Reverse Charge

Does reverse charge still apply on Amazon in 2024/2025?
Yes – partially. Amazon no longer applies reverse charge to most seller fees, which are now billed with local VAT through German (or other local) entities. However, for B2B goods sales you make to businesses in other EU countries, the legally separate principle of exempt intra-Community supplies applies instead.

Why am I receiving gross invoices from Amazon now instead of net invoices?
Since 1 August 2024, Amazon bills most German sellers through its local German entity. This means invoices now carry 19% German VAT, which Amazon withholds from your payout. You can claim this back as input tax.

How do I book Amazon fees correctly since August 2024?
Invoices with explicit German VAT are booked as standard input tax (DATEV key 401). Invoices from foreign Amazon entities without VAT are still booked with the § 13b reverse charge key. Amainvoice classifies these automatically.

Do I still need to verify my B2B customers' VAT IDs?
Yes, absolutely. The BFH ruling only applies to B2B services. For the physical B2B shipment of goods within the EU, verifying the customer’s VAT ID is a material requirement for tax exemption. If you fail to verify it, you lose the VAT exemption and will be held personally liable for the taxes.

What happens if I book a reverse charge invoice incorrectly?
The tax office can issue retroactive VAT assessments, plus interest and surcharges. For high-volume sellers, booking errors across multiple transactions can add up to significant sums very quickly.

Do I need to file a Recapitulative Statement for reverse charge sales?
Yes. All B2B intra-community supplies where reverse charge applies must be reported in the Recapitulative Statement (ZM) to Germany's Federal Central Tax Office (BZSt).

What does Amainvoice do to handle reverse charge?
Amainvoice automatically checks VAT IDs, generates legally compliant net invoices with the correct tax-exemption or reverse-charge wording (depending on whether it is a goods sale or a service), classifies incoming Amazon invoices by tax treatment, prepares ZM-relevant data, and exports everything DATEV-ready. → Start your free trial

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This article is for general informational purposes only and does not constitute tax or legal advice. Please consult a qualified tax advisor for guidance specific to your situation.