Amazon commingling and VAT: how to check and book it

Do you see commingling lines in your Amazon VAT Transactions Report (AVTR)? Neither the German VAT Act nor the Amazon report has a booking rule for them. Find the lines, document them separately from ordinary sales, clarify the treatment with a tax adviser, and only then carry them into the advance return.

Last updated: 27 October 2026

In short

Records: keep records that show the tax and its basis of calculation (§ 22 (1) sentence 1 UStG).
Retention: accounting vouchers for eight years, books and records for ten years (§ 147 (3) sentence 1 AO).
Responsibility: per Amazon, you are responsible for the accuracy of data you use for reporting or tax purposes.

What is commingling, and why is it in the tax report?

Amazon lists commingling transactions (Vermischungstransaktionen) in the VAT report as transactions of their own.

The AVTR is a monthly report with detailed data on the taxable transactions on the European marketplaces and in Amazon's logistics network. According to Amazon it includes sales, refunds, returns, cross-border inbound shipments, transfers between fulfilment centres, commingling transactions, liquidations, donations and Amazon service fees. How to use the report for your return: Amazon VAT report and the German VAT return.

What does the law require of me?

The law has no special chapter on commingling. The general duties apply: a business must keep records from which the tax and the basis of its calculation can be determined (§ 22 (1) sentence 1 UStG). Accounting vouchers must be kept for eight years, books and records for ten years (§ 147 (3) sentence 1 AO). How you classify a transaction in your case, whether it is taxable, in which country and whether it triggers a registration duty, depends on your inventory and shipping routes. A rule of thumb from a forum does not help here; ask a tax adviser or the tax office.

How do I proceed step by step?

Download the report. Get the AVTR for the period. Amazon advises: if a transaction is missing, check whether the transaction type is supported by the AVTR and whether the transaction was completed in the chosen reporting period.
Mark the lines. Find the rows Amazon shows as commingling transactions and keep them apart from ordinary sales.
Mind the period. Fee data for a month appears in the next month's report; the ACTIVITY_PERIOD column shows which month a fee belongs to. You deduct the input VAT on an Amazon fee invoice only once you hold the invoice (§ 15 (1) sentence 1 no. 1 sentence 2 UStG), so not yet for the ACTIVITY_PERIOD month if the invoice is issued in the following month.
Clarify the treatment. Discuss with your tax adviser how the lines are to be treated in your case before they go into your advance return or OSS return.
Document and keep. Store the original report unchanged. It is your evidence.

If this affects you in several EU countries, these pages help with the question of registration or OSS: OSS vs local VAT registration in EU countries and Amazon and OSS.

How VAT GPT helps

By hand, you pick the commingling lines out of a long file. VAT GPT helps with the groundwork:

Upload the report: your Amazon CSV (AVTR). VAT GPT recognises the Amazon report by its header row and notices when you upload the same file a second time.
Check: VAT GPT classifies each row by TAX_REPORTING_SCHEME: UNION-OSS as OSS, REGULAR in Germany as domestic, REGULAR in another country as local VAT; unknown values stay visible for your review.
Advance return: VAT GPT prepares the advance VAT return, and with VAT GPT Pro you send it via ELSTER. How a commingling transaction is treated for tax is something you clarify beforehand with your tax adviser.

There is Free (basic features, free of charge), Go (30 days free with all Pro features) and Pro (€49 per month or €444 per year, each including VAT). Try for Free Now

Which mistakes happen often?

Treating commingling lines like ordinary sales. They are their own kind of transaction and should be documented separately.
Classifying by the line label alone. Whether and where a transaction is taxable follows from your case.
Overwriting the original report. If you edit the file, you lose the unchanged evidence.
Deducting input VAT on fees too early. Fees appear in the next month's report; you deduct the input VAT only once you hold the invoice (§ 15 (1) sentence 1 no. 1 sentence 2 UStG).
Relying on forum answers. They replace neither the law nor advice.

Frequently asked questions

Where do I find commingling in the Amazon VAT report? The AVTR lists commingling transactions.

Do I have to put commingling lines in my VAT return? That depends on the classification in your case. Clarify it with a tax adviser or the tax office before you include or leave out the lines.

How long do I keep the report? As an accounting voucher eight years; if it serves as your record under § 22 UStG, ten years (§ 147 (1) no. 1 and 4, (3) sentence 1 AO).

Am I responsible for the data in the Amazon report? According to Amazon, you are responsible for the accuracy of the data you use for reporting or tax purposes.

Does one report show all transactions of a month? Not always: fees for a month appear in the next month's report, and a report covers at most 93 consecutive days.