Digital submissions; proof of registration; deadline clarifications

Germany’s Federal Ministry of Finance (BMF) has updated the rules for getting VAT refunded if your business is based outside the EU. The new guidance, issued on 27 March 2025, explains how to submit invoices and prove business status more easily in the digital age.

Read more in our German VAT guide.

Who Can Claim VAT Refunds in Germany?

Foreign businesses that are not established in the European Union can reclaim German VAT paid on local expenses, such as:

The procedure, often referred to as the input VAT refund or VAT reimbursement procedure, allows these companies to recover the VAT they are charged—provided they follow strict documentation rules.

Key Changes to the Refund Procedure

The latest BMF letter introduces important updates that make the process more digital and flexible:

1. Electronic Invoices Are Now Accepted

Previously, businesses needed to provide original paper invoices and import documents when filing for a refund. Under the new guidance, if you receive electronic invoices—such as PDFs or structured e‑invoices—they can be submitted electronically instead of on paper.

Businesses now have three options for submitting their invoices and supporting documents:

  1. Upload them directly via the Federal Central Tax Office (BZSt) online portal, known as the BOP.

  2. Submit them electronically with the application in the BOP.

  3. Provide them on a storage device, such as a USB stick, if requested.

This approach eliminates the need to ship physical files and aligns Germany’s process with modern e‑invoicing standards.

2. Proof of Business Registration Still Required

To qualify for a VAT refund, non‑EU businesses must prove that they are recognized as a business in their home country. This requirement has not changed, but the process has been clarified and digitized.

  • Companies must submit the USt 1 TN certificate or a digital certificate with the same content.

  • This certificate confirms that the company is a registered entrepreneur with a valid tax number.

  • The certificate must be presented to the BZSt either electronically or along with the VAT refund application.

3. Extended Deadlines and Flexible Submissions

The update also clarifies when and how supporting documents can be submitted. Non‑EU businesses can now:

  • Submit invoices and import documents up to the end of the application period

  • File their refund application online first, then upload or provide supporting files separately

This flexibility is especially helpful for businesses that work with multiple suppliers or invoice formats, making it easier to organise and submit claims without missing deadlines.