Due to increasing digitalisation, supporting documents to be submitted to the German tax authorities must be provided in digital form. The application for input VAT refunds must be accompanied by a detailed breakdown of the input VAT amounts to be refunded, and a threshold for the submission of invoices has been introduced. The breakdown of the invoices is usually submitted by filling-out the electronic application form on the online portal of the Federal Central Tax Office. In exceptional cases, it is also possible - on a transitional basis - to submit the breakdown of the invoices on a storage medium (e.g. a USB stick). The underlying invoices and customs assessment notices only need to be submitted if the total invoice amount exceeds 250 euros. In this respect, the general obligation to submit small-value invoices no longer applies. Nevertheless, it should be noted that these must be submitted if they are specifically requested by the Federal Central Tax Office. The invoices and customs assessment notices to be submitted must also be uploaded electronically via the Federal Central Tax Office’s online portal as part of the application or, in exceptional cases, submitted on a storage medium. However, this does not release the entrepreneur from their retention period and, where applicable, the obligation to submit the original documents.
In addition to the application itself and the invoices to be refunded, a certificate of entrepreneurship from the country of residency must be submitted, which must comply with the USt 1 TN template:
The certificate confirming entrepreneurship must also be submitted electronically with the application (i.e. scanned, if necessary). It should also be noted that the original certificate must be provided upon request by the Federal Central Tax Office.
Applications for input VAT refunds are subject to strict (formal) requirements which entrepreneurs must observe. Furthermore, applications for input VAT refunds submitted after 31 December 2025 should be reviewed, as the regulations come into force retroactively. Where necessary, applications for input VAT refunds that have already been submitted must therefore at least be supplemented.
This article was written in collaboration with Dr. Mario Wagner.