VAT for Non-EU Countries 2026: Invoicing, Reverse Charge & Import VAT
Diana
Updated on:
The moment your client sits in the US, Switzerland, the UK, or any other non-EU country, your VAT obligations shift. This guide walks through when to invoice at 0 %, when reverse charge kicks in, which countries count as a "third country" (Drittland), and how to handle import VAT correctly — with 2026 thresholds, statute references, and SKR03/SKR04 bookkeeping entries.
TL;DR in 30 seconds
Third country = any country outside the EU (including Switzerland, UK since 2021, USA, China, Norway, Iceland, Liechtenstein — the last three belong to the EEA but are treated as third countries for VAT).
B2B service to a non-EU business: Invoice without VAT, add the note "Reverse charge / Steuerschuldnerschaft des Leistungsempfängers" (§3a para. 2 UStG).
B2B goods export: Exempt under §4 No. 1a in conjunction with §6 UStG — export proof (Ausfuhrnachweis) is mandatory.
Inbound service from a non-EU business: Reverse charge under §13b UStG — you owe German VAT but can reclaim it as input tax in the same VAT return.
Importing goods: Import VAT (19 % or 7 %) applies to the customs value; the old €22 threshold was abolished on 1 July 2021.
What counts as a "third country"? (§1 para. 2a UStG)
Under German VAT law, a third country (Drittland) is any territory outside the EU single market (the 27 member states). For the broader VAT fundamentals, see our guide to German VAT.
Important: "Third country" is not the same as "non-EEA." Iceland, Liechtenstein, and Norway belong to the EEA but are treated as third countries for VAT purposes. For you, the rules are the same as for the USA.
Is [country] a third country? — Quick reference
Country | Third country? | Notes |
|---|---|---|
USA | ✓ Yes | No federal VAT — only state-level sales tax |
Switzerland | ✓ Yes | Own MWST system (8.1 % standard rate) |
United Kingdom | ✓ Yes (since 01.01.2021, Brexit) | Northern Ireland: special regime for goods |
China | ✓ Yes | VAT 6–13 % depending on supply type |
Japan | ✓ Yes | Consumption Tax 10 % |
Canada | ✓ Yes | GST/HST/PST by province |
Australia | ✓ Yes | GST 10 % |
Norway | ✓ Yes (EEA, but third country) | MVA 25 % |
Iceland | ✓ Yes (EEA, but third country) | VSK 24 % |
Liechtenstein | ✓ Yes (EEA, customs union with CH) | Follows Swiss MWST |
Turkey | ✓ Yes | KDV 20 % |
Russia | ✓ Yes | VAT 20 % |
Austria | ✗ No (EU) | Intra-Community supply |
Poland | ✗ No (EU) | Intra-Community supply |
Edge case — Helgoland / Büsingen / Canary Islands / Ceuta / Melilla: These are geographically part of Germany or Spain, but are third-country territory for VAT. Supplies there are export supplies.
Service or goods? B2B or B2C? The matrix that decides everything
German VAT treatment hinges on two questions:
Is this a service (sonstige Leistung) or a supply of goods (Lieferung)?
Is the customer a business (B2B) or a private individual (B2C)?
These four cases cover ~95 % of non-EU situations:
B2B (business customer) | B2C (private individual) | |
|---|---|---|
Service | Place of supply in the third country (§3a para. 2) — reverse charge, invoice without VAT | Place of supply in Germany (§3a para. 1) — 19 % German VAT, with exceptions under §3a para. 4 (catalogue services) |
Goods | Export supply §6 UStG — exempt with export proof | Export supply §6 UStG — exempt with export proof |
Invoicing a non-EU client: what goes on the invoice
B2B service to a non-EU business
The rule: Under §3a para. 2 UStG, the place of supply is where the recipient's business is located. If that's outside the EU, the transaction is not taxable in Germany.
Your invoice should include:
Net amount, no VAT line
Note: "Reverse charge" or "Steuerschuldnerschaft des Leistungsempfängers" (recommended; required inside the EU — not strictly required for third countries, but it protects you in a tax audit)
Optional English note: "VAT not applicable — place of supply in [Country]"
Your own VAT ID or tax number
A VIES lookup isn't possible outside the EU — document the recipient's business status differently (company registration extract, tax ID, website, order on company letterhead).
Rule of thumb: Outside the EU there is no VIES check. Keep evidence of the customer's business status in your files.
If you regularly work through US-based platforms like Upwork, Fiverr, or Patreon, see our guides on Upwork and German taxes and OnlyFans income and German tax — both are classic non-EU scenarios.
Goods export to a non-EU country
The rule: Exempt under §4 No. 1a in conjunction with §6 UStG, provided you hold the export proof (ATLAS-Ausgangsvermerk) and the documentary evidence.
Invoice must include:
Net amount, no VAT line
Note: "Tax-free export supply pursuant to §4 No. 1a in conjunction with §6 UStG" (German wording preferred by the Finanzamt)
Incoterms (DAP, FCA, etc.) recommended
Attach or reference the ATLAS export reference number (MRN)
B2C service to a private individual in a non-EU country
Place of supply under §3a para. 1 UStG is Germany — you generally charge 19 % German VAT.
Important exception — §3a para. 4 UStG (catalogue services): If the service is one of those listed (consulting, advertising, data processing, translation, electronically supplied services, etc.) and the private customer lives in a non-EU country, place of supply is the third country — so it's not taxable in Germany.
Invoice template for non-EU clients
You can issue non-EU compliant invoices directly in Norman — the correct wording and statute references are inserted automatically. Create invoices with Norman →
Example invoice to a US business client:
Receiving an invoice from a non-EU supplier: reverse charge under §13b UStG
When you buy a service from a non-EU business — think Dropbox, AWS, Google Workspace, Zoom, Figma, Slack, OpenAI — §13b para. 1 UStG applies. As the German recipient you owe German VAT on the net amount.
How this works in practice:
The US vendor issues an invoice without VAT, often with a note like "Reverse charge."
You apply 19 % to the net amount yourself (notional VAT liability).
In the same VAT return you claim the same amount as input tax.
Net cash effect: €0 — but both sides must appear in the return.
For a deeper dive into how output VAT and input VAT interact, see VAT, input tax, and the VAT return.
Accounting entry — SKR03
Accounting entry — SKR04
VAT return lines (UStVA)
Line 46 (codes 52/53): Taxable services received from a supplier based abroad
Line 58 (code 67): Input VAT from §13b UStG transactions
When are VAT pre-returns due? Our UStVA deadlines for 2026 article has the full calendar.
Watch out — small-business (Kleinunternehmer) rule §19 UStG: You still owe the §13b VAT, but you cannot claim it back as input tax. That means your Dropbox / AWS / OpenAI subscription is effectively 19 % more expensive. This trips up a lot of solo founders. Read more in Kleinunternehmer small-business rule.
Import VAT (Einfuhrumsatzsteuer / EUSt) in 2026
Importing physical goods into Germany triggers import VAT, collected by customs or the parcel courier.
Current 2026 thresholds
Threshold | What it means |
|---|---|
€22 | Abolished since 01.07.2021 — the old low-value exemption no longer applies |
€1 | Minimum import VAT amount — below this, no VAT is collected |
€45 | Gift allowance for private individuals (if declared as a gift) |
€150 | Duty-free, but still VAT-liable; IOSS available for online sellers |
> €150 | Customs duty + import VAT + any excise duties |
How import VAT is calculated
Taxable base = customs value + customs duty + transport/insurance to the first EU destination.
Example: machine imported from China
IOSS (Import One-Stop Shop)
For B2C goods imports up to €150, non-EU merchants can use the IOSS scheme. Import VAT is collected at checkout — the end customer doesn't get hit with a surprise charge at customs.
Reclaiming import VAT as input tax
If you're a VAT-registered business, you deduct import VAT as input tax on your VAT return (line 55, code 62). Net effect: €0.
Chain and triangular transactions involving a third country
In a chain transaction with a non-EU leg (e.g., DE → PL → CH), you need to identify which leg is the "moved supply" — only that leg can be VAT-exempt.
The classic intra-Community triangular simplification (§25b UStG) applies only within the EU. The moment a third country is involved, you fall back on the general export / import rules.
Kleinunternehmer §19 UStG and non-EU business
Outbound: You invoice without VAT anyway (small-business rule) — a reference to §19 UStG is enough.
Inbound (reverse charge): You still owe the §13b VAT, with no input-tax deduction. That SaaS subscription from the US now costs you 19 % more.
Goods import: Import VAT is due; you can't reclaim it.
For small-business owners, buying from non-EU vendors is genuinely more expensive than for a standard VAT-registered business. Full details: Kleinunternehmer small-business rule in Germany.
Country-specific notes
USA 🇺🇸
B2B service: Invoice without VAT, reverse-charge note. The US has no federal VAT, only state-level sales tax — in most cases your US customer has no VAT duty on your service.
Goods export: Export supply under §6 UStG — exempt; the US importer pays duty and possibly state sales/use tax.
Buying US SaaS: §13b UStG kicks in — you self-account for 19 % German VAT.
For freelancers working with US platforms: Upwork and German taxes · OnlyFans and German tax.
Switzerland 🇨🇭
B2B service: Swiss reverse charge ("Bezugsteuer") kicks in for the Swiss recipient if they're MWST-registered (CHF 100,000 annual turnover threshold).
Construction and architecture services performed in Switzerland may force you into Swiss VAT registration — don't skip a check with a Swiss tax advisor.
Goods export: Export supply — exempt; the Swiss importer pays Swiss MWST (8.1 %) at the border.
United Kingdom 🇬🇧 (post-Brexit)
Third country since 01.01.2021 — before that, EU.
B2B service: Reverse charge applies (the UK has a system comparable to §13b).
Goods: Export supply; the UK importer pays UK VAT (20 %) + any duty.
Northern Ireland Protocol: For goods shipped to Northern Ireland, the EU regime still applies — treat it like an intra-Community supply, but use an XI VAT number instead of GB.
China 🇨🇳
Third country; VAT system 6–13 % depending on supply type.
B2B service: Invoice without VAT, reverse-charge note. The Chinese importer handles Chinese VAT (often via withholding).
Recurring China-based supply chains may require a Chinese VAT registration — check case by case.
ViDA: what changes between 2027 and 2030?
The EU directive "VAT in the Digital Age" (ViDA) was adopted in March 2025 and rolls out in three waves:
2027: New rules for the platform economy (Airbnb, Uber, online marketplaces) — including non-EU platforms with EU users.
2028: Single VAT Registration — one registration for EU-wide B2C business.
2030: Mandatory Digital Reporting Requirements (DRR) and cross-border e-invoicing.
For non-EU businesses selling into the EU, this means IOSS and OSS are expanding and registration requirements are being streamlined.
Let Norman handle non-EU VAT for you
Norman automatically detects whether a transaction crosses the EU border, applies the right VAT treatment, books §13b reverse-charge transactions cleanly in SKR03 or SKR04, and submits your VAT return directly to ELSTER.
FAQ: VAT for non-EU countries
Is the USA a third country?
Yes. The USA is a third country for VAT. For services to US businesses, invoice without German VAT and add a reverse-charge note. The US itself has no federal VAT, only state-level sales tax.
Is Switzerland a third country?
Yes. Switzerland is neither an EU nor an EEA member and counts as a third country. Swiss B2B customers self-account for Swiss VAT (Bezugsteuer) if they're MWST-registered (CHF 100,000 threshold).
Is the UK a third country since Brexit?
Yes, since 01.01.2021. For goods to Northern Ireland the EU regime still applies — use an XI VAT number.
Do I add VAT on an invoice to a non-EU client?
B2B services and goods exports: no. For B2C services the §3a UStG rules apply — default 19 % German VAT, unless the catalogue-service exception in §3a para. 4 kicks in.
What note should I put on a non-EU invoice?
B2B service: "Reverse charge / Steuerschuldnerschaft des Leistungsempfängers."
Goods export: "Tax-free export supply pursuant to §4 No. 1a in conjunction with §6 UStG."
Does reverse charge apply in every non-EU country?
No. Whether the other country has its own reverse-charge system is up to local law. From a German perspective you simply invoice without VAT — what the recipient does on their side is their obligation.
How do I book a non-EU invoice (SKR03/SKR04)?
SKR03: account 3125 against vendor; input VAT to 1577 against output VAT 1787. SKR04: account 5925 against vendor; input VAT to 1407 against output VAT 3837. The two entries cancel each other — net effect €0.
How do I reclaim import VAT?
On your VAT return as input tax (line 55, code 62). Keep the customs assessment notice or the ATLAS document as evidence.
Do I need a VAT ID for non-EU business?
No, not strictly. A VAT ID is required for intra-Community transactions inside the EU. For non-EU business, your regular tax number is enough.
Does the small-business rule (Kleinunternehmer §19 UStG) apply to non-EU business?
Yes, §19 UStG still applies. But: You still owe reverse-charge VAT on non-EU services and can't deduct it as input tax — your non-EU purchases effectively cost you 19 % more.
What about Helgoland, Büsingen, the Canary Islands?
They are geographically inside the EU but are third-country territory for VAT. Supplies there are treated as export supplies.
Does ViDA affect me?
Gradually from 2027 onwards — particularly around e-invoicing obligations and platform transactions. For pure non-EU services, §3a para. 2 UStG continues to apply as before.