Accounting for VAT on German exports

blobbyh

A quick question easily answered I hope! Does anyone here deal with German originated exports to other EC and non-EC countries as we've received conflicting information based on the opinions of two separate German accounting firms?

Ebner say that VAT should be charged on all German exports, regardless of where the client is.

Mazars GmbH say that similar rules apply as here in the UK, that supplies are zero rated to intra EC clients and the reverse charge rules apply providing we obtain the client tax numbers. If taxable goods or services are supplied to Switzerland or Norway, we should obtain a - quote - "Certification of Entrepreneurship" - issued by their tax authority. Unfortunately, Google doesn't recognise this term!

Our German office are still continuing to argue the toss that the first one is correct despite the latter opinion being offered by an international accounting firm rather than a local one. Typical Germans. Just value a third opinion that's all for anyone else who has suffered the same conflicts.

sdv

The way I have dealt with this in the past is to treat the exports as a ZERO rated. However, there is a separate form to be filled in every 3 months giving details of importers and the importer's VAT number.

The importer's VAT number also had to be written on our SALES invoice to claim it as a ZERO rated status, and ofcourse the invoice was addressed to one of EC countries.




The Notice 725 may be of some interest to you

http://customs.hmrc.gov.uk/channelsPortalWebApp/channelsPortalWebApp.portal?_nfpb=true&_pageLabel=pageVAT_ShowContent&id=HMCE_CL_000152&propertyType=document

blobbyh

Thanks sdv, but these are recruitment services supplied ("exported") from our German office to a French client so the HMRC rules don't strictly apply!

deanshepherd

I have never had the pleasure of dealing with Germany before but, as far as I understand it, the rules across the EU in this matter are exactly the same.

Since 1st January (and possibly before) the place of supply of services defaults to where the customer belongs i.e. France.

blobbyh

Yep, that's my opinion too but you know (or maybe you don't!) what the Germans are like? If they understand it then fine - they're very efficient in their comfort zones - but if they don't, then they're like headless chickens!

sdv

blobbyh wrote: »

Thanks sdv, but these are recruitment services supplied ("exported") from our German office to a French client so the HMRC rules don't strictly apply!

I appreciate that, but they are an indication of the similar rules in Germany and France because we all belong to the same ONE market.

Like Deanshepher, I am of the same opinion. What ever rules are applied to UK customers/suppliers, the same rules will be applied to German/French Customers and Suppliers.

I believe this is the same opinion as obtained by your company from an international accounting firm.

I believe the notice is clear in that there is only ONE market (EC) and therefore VAT Exempt will only to exports to outside CE countries, however, VAT is chargeable within the market but at a ZERO percent.


On the VAT RETURN there are separate boxed for ACQUISATION and SUPPLY to EC counties. You are required to fill in this boxes for statistical information purposes and to account for different VAT rates in different EC countries.

If your company is exporting from Germany will have to the equivalent to box 8/9 on UK Vat Returns, and same for the French Company.

Sorry posted this too late after your above posting!

deanshepherd

I think you are getting a bit confused sdv. You are talking about the rules for 'goods'. Services are treated differently.

blobbyh

Thanks both for your help. Now we just need to tell our German office administrators to toe the line!

sdv

deanshepherd wrote: »

I think you are getting a bit confused sdv. You are talking about the rules for 'goods'. Services are treated differently.

Thanks Dean

I must say I have only dealt with supplying goods to EC countries in the past. Treatment of services sound interesting. I shall have to look into this.

Once again thanks for your feedback.