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Intra-Community Supply for a GmbH in Germany 2026: Requirements, Invoice and Bookkeeping

What your GmbH needs in 2026 for a VAT-exempt intra-community supply: valid VAT ID, mandatory invoice note, proof of delivery and EC Sales List, explained step by step.

Category
Taxes
Updated
Author
Diana

If your GmbH or UG ships goods to a business in another EU member state, the supply can be VAT-exempt: it qualifies as an intra-community supply under § 4 No. 1 letter b in conjunction with § 6a of the German VAT Act (UStG). But only if every condition is met: a valid VAT ID, the correct invoice note, and complete documentary and bookkeeping proof. Get one detail wrong and the tax office will hit you with 19 % VAT after the fact. Here is the full 2026 guide.

In short: Your GmbH’s supply to another EU country is VAT-exempt when four things line up: the goods leave Germany, the buyer uses a qualified, checked VAT ID from another EU state, the invoice carries the §6a exemption note and is issued net without VAT, and you secure documentary proof (confirmation of arrival) plus a bookkeeping record. The turnover is reported on the VAT advance return (line 41) and on the EC Sales List by the 25th of the following month. Miss one building block and the exemption falls away; 19 % VAT becomes due.

What is an intra-community supply?

An intra-community supply (igL) occurs when your GmbH sells and ships goods from Germany to another business in the EU. Example: you are based in Berlin, sell a machine to a SARL in France and dispatch it there. Under German VAT law the supply is exempt because the French buyer accounts for the acquisition VAT in France: the EU-wide reverse-charge mechanism for B2B supplies.

Important: the exemption applies to B2B only. Sales to private customers (B2C) in other EU countries fall under the One-Stop-Shop scheme, a different set of rules covered in our separate OSS article.

Don’t confuse the two: an intra-community supply (movement of goods within the EU) is not the same as an export supply to a third country outside the EU (e.g. Switzerland or the USA). Both are VAT-exempt, but the proof differs: exports rely on the customs export confirmation, an igL on the confirmation of arrival. The mirror-image transaction on the buyer’s side, the intra-community acquisition under reverse charge, follows its own rules.

Conditions for the VAT exemption

For your GmbH supply to remain VAT-exempt, four conditions must be met cumulatively:

ConditionWhat it means in practiceProof
Movement of goodsThe goods physically leave Germany for another EU countryConfirmation of arrival, consignment note
Business statusThe buyer is a taxable business, not a private customerValid, checked VAT ID
Valid VAT IDBuyer uses a VAT ID from another EU member stateQualified confirmation (BZSt)
Acquisition VATThe acquisition is taxed in the destination countryFollows from the VAT ID

You must run a qualified VAT ID check before every supply; the easiest route is the online confirmation portal of the German Federal Central Tax Office (BZSt). A simple confirmation only tells you the number exists; the qualified confirmation also matches the buyer’s name and address, and only that one counts before the tax office. Save the confirmation as a PDF in the order file.

Mandatory invoice details

An invoice for an intra-community supply contains the standard fields under § 14(4) UStG plus three specific obligations:

  • Your German VAT ID, not the regular tax number.
  • The buyer’s VAT ID from the relevant EU member state.
  • Mandatory note: „VAT-exempt intra-community supply pursuant to § 4 No. 1 letter b in conjunction with § 6a UStG.“ Without this note the exemption can be denied.

VAT is not shown: you invoice net. Under § 14a UStG the invoice must be issued by the 15th day of the month following the supply. If you also need to handle B2B e-invoicing in Germany, the format requirements (XRechnung, ZUGFeRD) apply on top of the substantive VAT rules.

Free invoice template (PDF, Word & Excel)

Legally compliant with all mandatory fields under §14 UStG, three formats, ready to use.

Documentary proof: confirmation of arrival and the arrival presumption

You must prove that the goods left Germany, otherwise the finest exemption note is worthless. Since the EU “Quick Fixes” of 2020 there are two parallel routes to documentary proof:

  • National proof rules (§§ 17b, 17c UStDV): above all the confirmation of arrival (Gelangensbestätigung) from the buyer, backed by a consignment note or forwarder certificate.
  • EU-wide arrival presumption (Art. 45a of the VAT Implementing Regulation, § 17a UStDV): where an independent freight forwarder or carrier ships the goods, arrival is presumed if you hold at least two non-contradictory items of evidence from two independent parties.

Which proof fits which shipping method:

Shipping methodAccepted documentary proof
Freight forwarder (carrier)CMR consignment note signed by the recipient, or two independent items of evidence (arrival presumption)
Parcel service (DHL EU, UPS)Tracking record showing delivery in another EU country
Buyer collects the goodsConfirmation of arrival is indispensable
Transport by the GmbH itselfConfirmation of arrival + transport record

The confirmation of arrival must contain: the buyer’s name and address, the quantity and standard description of the goods, the place and month of receipt in the EU destination country, plus the date and the buyer’s signature. Keep all proof for ten years; it forms part of your GmbH bookkeeping records.

Bookkeeping proof and posting in the GmbH

On top of the documentary proof, you must keep a separate bookkeeping record. Intra-community supplies go on a dedicated revenue account (SKR03: 8125, SKR04: 4125), and for each transaction you record:

  • Buyer name and address
  • Buyer’s VAT ID with confirmation
  • Quantity and standard description of the goods
  • Date of supply and dispatch
  • Destination in the EU

With Norman, the AI detects an intra-community supply from the buyer’s VAT ID and posts to the right revenue account automatically; you only upload the document.

Collection vs. dispatch: who transports decides

An often underrated point: it makes a difference whether you dispatch the goods or the buyer collects them.

  • Dispatch case: your GmbH instructs a forwarder or parcel service. The transport document (CMR, tracking) provides strong proof.
  • Collection case: the buyer picks up the goods with their own truck. Here you have no transport document of your own, so the confirmation of arrival is mandatory, usually backed by authorisation from the person collecting. Without it the exemption in a collection case is hard to defend.

Especially when the customer collects, have the confirmation of arrival signed at handover; chasing it down later rarely works.

EC Sales List and VAT advance return

Every intra-community supply must be reported twice:

The key deadlines at a glance:

Filing / obligationDeadline
Issue the invoice (§ 14a UStG)by the 15th of the following month
EC Sales List (ZM)by the 25th of the following month
VAT advance return (UStVA)by the 10th of the following month
Keep the proof10 years

Skip the EC Sales List and you not only face late-filing penalties but can also lose the VAT exemption retroactively. Since 2020 a correct and timely EC Sales List is a substantive condition of the exemption, no longer just a formality. More on the general reverse-charge mechanism, the mirror image of the intra-community supply on the buyer’s side, in a separate article.

The process in four steps

Four steps to a VAT-exempt intra-community supply: verify the VAT ID, net invoice with the §6a note, secure the confirmation of arrival, file the EC Sales List and VAT return
From the VAT ID check to the EC Sales List: skip one step and the tax office charges 19 % VAT after the fact.
  1. Run a qualified VAT ID check and save the confirmation as a PDF.
  2. Issue a net invoice with your VAT ID, the foreign VAT ID and the §6a exemption note.
  3. Secure documentary proof: a confirmation of arrival or two independent transport records.
  4. File: enter the exempt turnover in VAT-return line 41 and submit the EC Sales List by the 25th.

Common mistakes and how to avoid them

  • VAT ID not checked qualified. Only the qualified online confirmation including name and address counts before the tax office.
  • Mandatory note missing. Without the exemption note you have to assess and remit VAT after the fact.
  • No confirmation of arrival. Indispensable when the buyer collects the goods themselves.
  • EC Sales List late or missing. Set fixed reminders for the 25th of every following month.
  • Mixed invoice. Exempt and taxable items belong on separate invoices, otherwise the whole revenue can become taxable.

Frequently asked questions

Who pays the VAT on an intra-community supply?

No one in Germany: your GmbH supplies VAT-free, and the buyer accounts for the intra-community acquisition in their own country under reverse charge. That is why the invoice shows no VAT.

What happens if the buyer’s VAT ID is invalid?

Then a substantive condition is missing: the supply is not exempt and you have to assess 19 % VAT after the fact. That is why the qualified check is mandatory before every supply, not just at first contact.

Do I always need a confirmation of arrival?

Not strictly, but it is the most practical documentary proof. In the dispatch case a CMR consignment note or two independent items of evidence under the EU arrival presumption also work. In the collection case there is practically no way around the confirmation of arrival.

What is the difference from an export supply?

An intra-community supply goes to another EU state; an export supply goes to a third country outside the EU (e.g. Switzerland, UK, USA). Both are VAT-exempt, but the proof differs: a customs export confirmation for exports, a confirmation of arrival for the igL.

Do I have to file an EC Sales List even for a single supply?

Yes. As soon as you carry out one intra-community supply in a reporting period, the EC Sales List is mandatory, regardless of the amount. Without a timely EC Sales List the exemption falls away retroactively.

Conclusion

An intra-community supply saves your GmbH 19 % VAT on every EU B2B sale, but only with airtight documentation. Check the VAT ID, add the exemption note, secure the confirmation of arrival, file the EC Sales List on time. With Norman you automate posting, VAT logic and EC Sales List preparation in one tool. For invoicing in the EU B2B format we recommend our e-invoicing solution with native XRechnung and ZUGFeRD support.

VAT-exempt EU supply: Norman checks, posts and files

Upload the document: Norman recognises the intra-community supply from the buyer’s VAT ID, posts it to the right revenue account automatically (SKR03 8125 / SKR04 4125), checks the invoice for the §6a exemption note, and prepares the exempt turnover for VAT-return line 41 and the EC Sales List. That keeps your GmbH’s EU B2B supply airtight and VAT-free. Try the AI bookkeeping for free.