Invoicing EU and Non-EU Clients From Germany: Reverse Charge Without the Guesswork

The sentence "Steuerschuldnerschaft des Leistungsempfängers" is legally required on one invoice and legally wrong on the next. Which one depends on who is on the other end. Here is the rule, then three invoices for the same €4,000 design job, sent to Berlin, Paris and New York.

The one rule that sorts every B2B invoice

§ 3a Abs. 2 UStG says that a service supplied to a business for its business is supplied "an dem Ort ... von dem aus der Empfänger sein Unternehmen betreibt". The place of supply is the client's seat, not your desk in Hamburg. German VAT applies only if that place is in Germany. Everything else follows from this.

Three consequences. Client in Germany: taxable here, you add 19%. Client in another EU country: taxable there, and EU law makes the client pay that VAT to their own tax office (the reverse charge); your paperwork sits in § 14a, § 18a and § 18b UStG. Client outside the EU: outside German VAT entirely; whatever is due there is the client's problem under local rules.

For private customers the default flips: § 3a Abs. 1 puts the place of supply at your seat, so German VAT applies, with exceptions for electronic services (Abs. 5) and for listed services such as consulting to private customers outside the EU (Abs. 4). This article stays with business clients.

Example 1: the client in Berlin

The invoice carries the mandatory details of § 14 Abs. 4 UStG, then:

• Web design, September 2026: €4,000.00
• plus 19% VAT: €760.00
• Total: €4,760.00
• Your Steuernummer or USt-IdNr, the client's address, no reverse-charge sentence.

The €760 goes into your Voranmeldung as output VAT. From 2028 this invoice must be an e-invoice; the mandate covers domestic B2B only, not the two cases below.

Example 2: the client in Paris

First check the client's French VAT number and keep the result. Two ways: the BZSt confirmation service, which forwards your query to the French authority and returns a data record you keep as proof (choose the qualified query, which also checks name and address), or the Commission's VIES search, which pulls from the same national databases and recommends keeping "track of your validation in case of a tax control". Screenshot, date, client folder. If the number is invalid, charge German VAT until the client fixes it; only they can correct their registration.

Then the invoice, following § 14a Abs. 1 and 5 UStG:

• Web design, September 2026: €4,000.00
• Total: €4,000.00
• Your USt-IdNr: DE123456789
• Client's USt-IdNr: FR12345678901
• "Steuerschuldnerschaft des Leistungsempfängers" (optionally add "Reverse charge, VAT to be accounted for by the recipient")
• No tax rate, no tax amount, no "0%".

Four things people get wrong. The German sentence is what § 14a prescribes; an English line next to it is fine, an English line instead of it is not. You do not write "0% VAT": § 14a Abs. 5 says the tax-rate requirement of § 14 Abs. 4 Nr. 8 does not apply, and a 0% line invites the question of which exemption you mean. The invoice has a deadline, the 15th day of the month after the month of supply (§ 14a Abs. 1), which bites if you invoice quarterly. And you need your own USt-IdNr, which the BZSt issues free of charge to any business under § 2 UStG, via your Finanzamt or online.

Two filings follow. In the Voranmeldung, § 18b UStG requires the €4,000 in a separate line as a § 3a Abs. 2 service taxed by the recipient. By the 25th after the end of the quarter, § 18a Abs. 2 UStG requires a Zusammenfassende Meldung to the Bundeszentralamt für Steuern with the client's USt-IdNr and the amount. The ZM is how the French tax office learns your client should have declared €4,000 of reverse-charge VAT. Miss it and the mismatch surfaces on their side first.

Example 3: the client in New York

Same rule, different paperwork. § 3a Abs. 2 puts the place of supply in the US, so the invoice is outside German VAT. No EU reverse charge to point to, no ZM. But you must be able to show the client is a business, because for a private customer the place of supply would flip back to Germany for most services. Per OFD Niedersachsen guidance from 2015 as reported by Haufe, the authorities accept a certificate from the client's tax authority or, failing that, "eine Mehrwertsteuernummer oder eine ähnliche vom Dienstleistungsempfänger von seinem Ansässigkeitsstaat zugeteilte Nummer". In practice: EIN or state registration, register extract, website, signed contract, all in the client folder.

• Web design, September 2026: €4,000.00 (or the USD equivalent, with the euro amount stated)
• Total: €4,000.00
• Your USt-IdNr or Steuernummer
• Client's business identifier (e.g. EIN) and full business address
• "Nicht im Inland steuerbare Leistung, Leistungsort § 3a Abs. 2 UStG" (English: "Not subject to German VAT, place of supply outside Germany")
• No tax rate, no tax amount.

In the Voranmeldung this amount goes into the line for other non-taxable turnover with the place of supply abroad, not into the EU-only § 18b line. Whether US sales tax applies is the client's question. Switzerland and the UK are Drittland for this purpose too; the Swiss UID is the worked example in that OFD guidance.

The mirror case: when you buy from abroad

The same logic runs in reverse. Google Ads billed from Ireland, a US SaaS subscription, a designer in Poland: each is a service supplied to your business, so the place of supply is Germany, and under § 13b Abs. 1, 2 and 5 UStG you owe the German VAT as the recipient. You declare 19% on the net amount in your Voranmeldung and, if entitled to input VAT, deduct the same amount in the same return. Net zero, but only if you file it. This is why those suppliers ask for your USt-IdNr and invoice without VAT.

The Kleinunternehmer special case

If you use the § 19 UStG small business scheme, the exemption covers your own supplies made in Germany. A service to a Paris business is supplied in France, so § 19 does not touch it: the client reverse-charges French VAT, and you still need a USt-IdNr and the § 14a sentence on the invoice. The one relief: § 18a Abs. 4 exempts you from the Zusammenfassende Meldung.

The trap runs the other way. Buy that US software as a Kleinunternehmer and § 13b makes you owe 19% German VAT on it, with no input VAT to offset. A €100 subscription costs €119, payable via a Voranmeldung you otherwise would not file.

What to do on Monday

1. Sort your client list into three columns: German business, EU business, non-EU business. Each column is one invoice template.
2. Run every EU client's USt-IdNr through the BZSt qualified query or VIES once a year and at the start of every new engagement. Screenshot, date, folder.
3. Check the last EU invoice you sent for the exact sentence "Steuerschuldnerschaft des Leistungsempfängers" and the absence of a 0% line. Fix the template.
4. Ask each non-EU client for a business identifier and file it with the contract. Two minutes now saves a reclassification later.
5. Set the ZM deadline, the 25th after each quarter, in your calendar next to the Voranmeldung. An invoicing tool that produces the ZM data for you, such as Accountable (affiliate link), removes the manual step; the 9am Freelancer Toolbox lists alternatives.

If working across borders is your model, the tax questions do not stop at VAT; our legal guide for digital nomads covers residence and where your income tax lands. And if your client list is still mostly in one column, a free 9am profile adds the other two: companies across Germany, Austria and Switzerland hire through it, and Austria and Switzerland are examples 2 and 3.

This article is general information for practitioners and does not replace tax advice. Cross-border VAT depends on the type of service; have your own setup checked before you change a template.