Taxable businesses and self-employed persons in Germany are required to file a value-added tax (VAT) return with the tax office once a year. This return includes a main form called “USt 2A” and an additional form called “Annex UN” (“Anlage UN” in German). The main form is mandatory, but the Annex UN form is not required for all businesses.

In this article, we explain the Annex UN form, including when to fill it out and what information to provide. We also explain the associated audit risks and include helpful tips on filing an Annex UN form.

What’s in this article?

• What is the Annex UN form, and when is it required?
  
• How do overseas businesses register for VAT in Germany?
  
• What information must be provided on the Annex UN form?
  
• What documents must businesses file with the Annex UN form?
  
• Audit risks associated with the Annex UN form
  
• Practical tips for filing an Annex UN form
  

What is the Annex UN form, and when is it required?

The Annex UN is a special form that is part of the annual VAT return. Overseas business owners who do not have residence, commercial premises, or management in Germany but generate revenue subject to VAT in Germany must file this form. For example, this includes supplies of goods from German warehouses or services rendered domestically. A correctly completed Annex UN form must be submitted to properly satisfy the regulations of the German VAT Act (UStG).

In Germany, overseas businesses are, in principle, also required to file preliminary VAT returns and tax returns if they generate taxable revenue in Germany or maintain commercial premises in the country. According to Section 18, Paragraph 4a of the UStG, this also applies to business owners and legal entities that generate revenue exclusively from supplies of vehicles, intracommunity triangular transactions, reverse charge supplies, or intracommunity acquisitions in Germany.

How do overseas businesses register for VAT in Germany?

Overseas businesses generating taxable revenue in Germany must apply for a German VAT identification number (VAT ID) from the Federal Central Tax Office (BZSt). The BZSt issues VAT IDs based on the data held by the relevant tax office. Therefore, overseas businesses have to first register for VAT with their local tax office.

According to Section 21, Paragraph 1 of the German Fiscal Code (AO), individual states are assigned to specific tax offices. For example, requests from businesses in Estonia are processed by the Rostock Tax Office, while the Munich Tax Office handles requests from Italy. A detailed overview of which tax office is responsible for which states can be found in the German Ordinance on VAT Jurisdiction (UStZustV). If the overseas company has a branch in Germany, its responsible tax office is the tax office located in the same district as the company’s branch.

Applying for a VAT ID

You can apply for a VAT ID from the BZSt in writing or online. Here’s a step-by-step walkthrough of the process:

• Fill out the application form
  The application form captures information on your company, business activity, and estimated revenue. It’s important that you provide complete and correct information because failure to do so can delay the application process.
  
• Submit your documents
  The BZSt will request certain pieces of documentation so it can verify the identity of your business. This includes a certified copy of your company information record or other forms of official ID.
  
• Wait for review
  Once it has received your application, the BZSt will review the information and the documentation you have provided. This process can take several weeks, depending on the amount of documents submitted and the complexity of the application. In some cases, the BZSt can request additional information or documentation during its review.
  
• Receive your VAT ID
  Businesses that successfully pass review are issued a VAT ID by the BZSt via mail. From this point on, the company must state its VAT number on invoices and other business documents if it provides services subject to VAT in Germany. They are also obligated to file VAT returns and pay tax.
  

One Stop Shop (OSS) and Import One Stop Shop (IOSS) options

Some businesses can also opt for OSS when registering for VAT. The OSS is an EU system for processing VAT in cross-border ecommerce. It is aimed at businesses that deliver goods to private customers in other EU member states or render services for customers in member states in which they are not domiciled. Businesses that use OSS can report their revenue via a central online portal rather than registering in each country individually. OSS is a voluntary program, but it’s worth signing up—especially if you’re an online retailer selling products or services in multiple EU countries.

Businesses that sell goods imported from third countries to customers in the EU can use the IOSS program. The IOSS is another electronic system intended to simplify cross-border commerce. It was introduced in 2021 as part of the EU’s VAT reforms and—similar to OSS—provides one-time registration on a digital platform. However, IOSS is restricted to distance sales of goods to customers up to a maximum value of €150.

What information must be provided on the Annex UN form?

The Annex UN form in the VAT return is a one-page form that contains twenty boxes. Use this form to provide the following company details.

General information

• Box 1: Tax ID
  
• Box 2: International Bank Account Number (IBAN)
  
• Box 3: Bank Identifier Code (BIC)
  
• Box 4: Name of financial institution and town or city
  
• Box 5: Account number, for bank accounts outside the Single Euro Payments Area (SEPA)
  
• Box 6: Name of account holder
  

Businesses have the option of appointing an authorized representative to observe their tax rights and obligations. They can also designate an authorized recipient to receive correspondence. However, these proxies cannot be used for tax refunds and rebates. Businesses provide the following information about proxies in Boxes 7–15 of the Annex UN form:

• Box 7: Authorized proxies (two options to check)
  
• Box 8: Name
  
• Box 9: Street
  
• Box 10: House number and additional address information
  
• Box 11: ZIP code and town or city
  
• Box 12: ZIP code and PO Box
  
• Box 13: Telephone number
  
• Box 14: Email address
  
• Box 15: Confirmation that the VAT return has been signed by the authorized proxy (check as applicable)
  

Input VAT rebate procedure

Box 16 of the Annex UN form in the VAT return asks whether a business carried out any input VAT rebate procedures with the BZSt in the corresponding calendar year. If it did, then the company must attach invoices and import receipts as evidence of its deductible input tax. In addition, on the main form of the VAT return, businesses can only indicate input tax that the BZSt has not yet refunded as part of the VAT rebate procedure.

VAT credits

In Box 17, companies indicate whether VAT paid under the individual transport taxation procedure should be credited. The VAT paid is entered as an amount in euros and must be evidenced by relevant supporting documents. The same applies to Box 18 for security deposits paid in accordance with Section 18, Paragraph 12, Sentence 5 of the UStG. The two amounts are added together in Box 19.

Additional information

Finally, Box 20 of the Annex UN form is used to specify the amount generated from intracommunity distance selling with other European Community (EC) states. Again, businesses enter an amount in euros.

What documents must businesses file with the Annex UN form?

Below, you will find an overview of the most important documents that overseas businesses need to submit with the Annex UN form in the VAT return:

• Company information record: This includes evidence that the business exists and its legal structure.
  
• Proof of ID: This is confirmation of the business’s identity, such as a copy of the registration from the state of domicile.
  
• Mandate (where applicable): If the return is being filed by an authorized proxy, this includes evidence of legal authority.
  
• Invoices and import receipts for input tax: This is the basis for claiming input tax as part of an input tax rebate procedure with the BZSt.
  
• VAT receipts under the individual transport taxation procedure (where applicable): This includes documentation of VAT incurred under this procedure.
  
• Receipts for securities (where applicable): Include evidence of securities provided to the tax authorities.
  
• Invoices showing intracommunity distance selling (where applicable): This is supporting documentation for declaring taxable distance sales within the EU.
  

Audit risks associated with the Annex UN form

Submitting a complete and correct Annex UN form is important for overseas companies when filing their VAT return in Germany. Errors or oversights can lead to delays, extra administration effort, arrears, penalty interest, and fines. Most audit risks are the result of inaccurate or incomplete information and documentation.

Incorrect revenue reporting

When businesses generate revenue from supplies of goods or services in Germany but fail to report this correctly on the Annex UN form, their taxes are calculated incorrectly. It is particularly problematic for businesses to fail to report revenue generated domestically as taxable earnings or provide incomplete information concerning the services or goods provided. The tax office could consider this to be noncompliance with tax law and take action accordingly.

Missing or incomplete documentation

Missing or incomplete evidence can create issues during the review stage. This includes documents such as company information records, ID documents, invoices, and import receipts. The tax office can reject documents and request submission of new documentation. They could also suspend their review, leading to delays and additional costs.

Failure to provide evidence of distance selling thresholds

European businesses selling goods internationally to customers within the EU can pay VAT in their country—provided they do not exceed an annual threshold of €10,000. Above this limit, they have to remit VAT in the corresponding member state. Intracommunity distance sales have to be comprehensively documented, in addition to submitting the Annex UN form. This is the only way these businesses can prove that they have not exceeded the limit.

Late filing

Overseas businesses have to file their VAT return by July 31—as do their German counterparts. Failure to submit a return by the deadline could prompt the tax office to estimate the amount of tax to pay, which often comes out higher than necessary. There’s also the possibility of receiving fines, penalty interest, and other sanctions.

Practical tips for filing an Annex UN form

Filing the Annex UN form can be a challenge. Approaching it in a structured way can make the process much easier. Here are a few practical tips:

Plan early

Start prepping early so you’re not under pressure to complete the Annex UN form or your VAT return. The best way to do this is to collect and sort relevant documents throughout the year. Then, you can easily access the documents you need. This includes invoices, receipts, and proof of intracommunity supplies of goods or services. You should also allow yourself sufficient time to fill out your return or hire a professional, such as a tax advisor.

Provide consistent data

Make sure the information you provide in the Annex UN form is correct and complete. Check whether the data aligns with the information you have provided on other tax returns and in other systems. For example, if you file your tax returns via ELSTER—Germany’s website for submitting tax returns—and also use the OSS system, the data in both of these systems needs to be consistent.

Use automation

Many administrative processes can be automated to help you fill out your VAT return quickly and correctly. Stripe Tax helps overseas businesses fulfill their German VAT obligations in a number of ways.

For example, Tax automatically recognizes when taxable revenue is earned—giving you the right figures for your return. The system applies the correct VAT rate according to each type of transaction and destination country. Automatic identification of revenue eligible for reverse charge is particularly helpful. The tool also validates your customers’ VAT IDs using the EU’s VAT Information Exchange System (VIES) to ensure it is only accounting for legitimate transactions.

Plus, there’s no need to manually transfer the data generated in Tax to the Annex UN form. Tax compiles the data for the Annex UN form in an exportable format—saving you time and reducing the risk of errors.