Impact of Brexit on VAT Registration for UK Companies

Since Brexit, UK companies operating in Germany face significant changes in VAT registration requirements and compliance. This article delves into specific considerations and adjustments necessary for VAT compliance post-Brexit, including insights into the EORI number requirements and strategic solutions such as establishing a German GmbH to manage imports into the EU.

Changes in VAT Registration Post-Brexit

Following the UK’s exit from the European Union, UK companies conducting business in Germany must adhere to new VAT regulations to ensure compliance with German tax laws. These changes primarily affect VAT registration, reporting, and import/export procedures.

VAT Registration Requirements for UK Companies

Mandatory VAT Registration

UK companies selling goods or services in Germany post-Brexit must register for VAT with the German tax authorities (Finanzamt). This registration allows companies to charge and collect VAT on taxable supplies made in Germany and comply with local tax regulations.

VAT Representation Requirements

UK companies without a physical presence in Germany may need to appoint a fiscal representative for VAT purposes. The fiscal representative acts as a local agent responsible for VAT compliance and communication with German tax authorities on behalf of the UK company.

EORI Number Requirement

The Economic Operators Registration and Identification (EORI) number is essential for UK companies importing goods into the EU post-Brexit. The EORI number is used to track and identify businesses involved in customs activities.

Import Limitations for Non-EU Companies with EORI Number

According to current EU regulations, companies from non-EU countries, including the UK post-Brexit, with an EORI number are typically limited to three imports per year into the EU. This limitation aims to control customs activities and ensure compliance with EU import regulations.

Strategic Solution: Establishing a German GmbH

To navigate import limitations and facilitate unrestricted imports into the EU, UK companies may consider establishing a German GmbH (limited liability company). The German GmbH can obtain its own EORI number and act as the importer of record for goods imported from third countries into the EU.

Benefits of Establishing a German GmbH:

  • Unrestricted Imports: A German GmbH can conduct unlimited imports into the EU under its EORI number, bypassing the three-import limitation for non-EU companies.
  • VAT Compliance: The GmbH can manage VAT registration, compliance, and reporting in Germany, ensuring seamless operations within the EU market.
  • Subsidiary Structure: The German GmbH can operate as a subsidiary of the UK parent company, maintaining strategic control and integration within the corporate structure.

Practical Steps for Establishing a German GmbH

  1. Company Formation: Register the GmbH with the local commercial register (Handelsregister) in Germany.
  2. EORI Number Application: Apply for an EORI number for the GmbH through the German customs authorities (Zoll).
  3. VAT Registration: Register the GmbH for VAT with the German tax authorities (Finanzamt) to comply with local tax regulations.
  4. Operational Integration: Integrate the GmbH into the corporate structure as a subsidiary of the UK company, ensuring alignment with strategic goals and operational efficiencies.


The impact of Brexit on VAT registration for UK companies operating in Germany necessitates strategic adjustments to ensure compliance and operational continuity. By understanding VAT registration requirements, EORI number implications, and strategic solutions such as establishing a German GmbH, UK companies can navigate post-Brexit challenges effectively and maintain seamless business operations within the EU market.

For personalized guidance on VAT compliance and establishing a German GmbH, please contact us at Our team specializes in assisting international businesses with VAT registration and compliance in Germany.