Online marketplaces such as Amazon, Zalando, eBay, and others have become indispensable sales channels for both domestic and foreign sellers. However, Germany imposes strict VAT compliance rules on online sellers operating through these platforms. In recent years, marketplace operators have increasingly suspended accounts or withheld VAT amounts due to non-compliance.
This article explains the most common VAT-related problems faced by online sellers and what you should be aware of in 2025.
1. Background — Why Marketplaces Enforce VAT Compliance
Since 2019, Germany has introduced special VAT liability rules for online marketplaces. According to § 25e of the German VAT Act (UStG):
- Marketplaces such as Amazon, Zalando, and others may be held liable for unpaid VAT arising from sales made via their platforms.
- To avoid this liability, platforms require sellers to provide valid German VAT certificates (Bescheinigung nach §22f UStG) and proper VAT registration.
If the seller does not comply, the marketplace is legally obliged to:
- Block the seller’s account, or
- Withhold and remit the VAT directly to the German tax authorities.
This rule affects both German and foreign online sellers who deliver goods to German customers.
2. Typical Reasons for Account Suspension
Online sellers may face account suspension for:
- Missing or expired §22f VAT certificate in the marketplace system.
- Missing or invalid German VAT ID number.
- Late or missing VAT filings with the German tax office.
- Discrepancies between reported sales and VAT returns.
Suspensions often occur without prior warning and can lead to significant loss of turnover.
3. VAT Withholding by Marketplaces
In cases of missing compliance, marketplaces may apply the so-called VAT split payment:
- The platform withholds the German VAT from the seller’s proceeds.
- The withheld VAT is then paid directly to the German tax authorities by the marketplace.
- The seller only receives the net amount (sales price minus German VAT).
Although this prevents immediate VAT liability risks for the platform, it significantly impacts the seller’s cash flow and accounting.
4. How Can Sellers Prevent Account Suspension?
For both German and foreign sellers:
- Ensure you are properly VAT registered in Germany if required.
- Obtain and upload the valid §22f VAT certificate to your marketplace account.
- Submit correct and timely VAT returns.
- Regularly check communication from the German tax office and your marketplace.
Foreign companies, even if only storing goods in Germany via Amazon FBA or Zalando Fulfillment, will usually require a German VAT registration and compliance.
5. Special Challenges for Foreign Online Sellers
Foreign online sellers often underestimate:
- The obligation to register for VAT in Germany when using fulfillment centers.
- The complexity of German VAT invoicing and reporting rules.
- The risks of automatic VAT withholding by marketplaces without prior notice.
Professional VAT compliance is essential to ensure continued access to marketplaces.
6. Our Support for Online Sellers
At WW+KN, operating VAT-Germany.com, we regularly assist online sellers with:
- German VAT registration
- Filing of VAT returns
- Obtaining the required §22f VAT certificate
- Communication with marketplaces and German tax authorities
- Resolving account suspensions caused by VAT issues
Through our close cooperation with the VAT and legal specialists of Baker Tilly, we can also support you in case of disputes or more complex VAT problems.
Important Note
This article provides general information only and does not constitute legal advice. For an individual assessment of your case, we recommend obtaining professional advice.
If you have any questions regarding VAT registration, VAT returns, or marketplace compliance in Germany, please feel free to contact us.
We are WW+KN, a Baker Tilly Company.
You can reach us at info@vat-germany.com.
