VAT collected by Amazon: what it means for you

Amazon does not pay the VAT on every one of your sales. The law defines individual cases in which a marketplace counts as the supplier itself, above all for imported goods up to 150 euros intrinsic value (section 3(3a) UStG). For all other sales you remain responsible yourself, even if Amazon issues the invoice.

Last updated: 27 October 2026

In brief

Rule: every seller on Amazon is responsible for complying with VAT rules, says Amazon.
Exception: if a marketplace supports certain supplies, it is treated as if it had supplied itself (section 3(3a) UStG).
Allocation: whoever counts as the supplier owes the tax on that supply (section 13a(1) no. 1 UStG).
Not the same: whether Amazon holds back part of your payout does not tell you who owes the VAT; the law decides that (section 3(3a) and section 13a(1) no. 1 UStG).

When does Amazon count as the supplier?

The law knows two cases in which the operator of an electronic interface, that is a marketplace, is treated as the supplier.

In the first case the marketplace supports the supply of a good whose transport or dispatch begins and ends in the Community, by an entrepreneur not established in the Community, to a recipient who does not buy for a business, above all a private person (section 3a(5) sentence 1 UStG). It is then treated as if it had itself received the good for its business and supplied it (section 3(3a) sentence 1 UStG).

In the second case the marketplace supports the distance sale of goods imported from the third-country territory in consignments of an intrinsic value of no more than 150 euros. It then also counts as the supplier (section 3(3a) sentence 2 UStG).

An electronic interface is an electronic marketplace, an electronic platform, an electronic portal or the like (section 3(3a) sentence 3 UStG). Whether your sale falls into one of the two cases is decided by the law, not by the platform. As a seller based in Germany who sells goods from a warehouse in the EU, you normally do not have the first case, because it requires a seller outside the EU.

What does that mean for your VAT?

The tax debtor for a supply is the entrepreneur who makes it (section 13a(1) no. 1 UStG). If the marketplace counts as the supplier, it is the entrepreneur for that supply. If an entrepreneur has supplied goods to a marketplace that supplies them on within the Community under section 3(3a) sentence 1 UStG, that supply to the marketplace is tax-exempt (section 4 no. 4c UStG).

For everything else: you calculate the tax yourself and report it yourself, except where your business customer owes the tax (section 13b UStG). Amazon also says that every seller is responsible for complying with the applicable VAT rules. Which sales belong in your VAT return is shown in VAT return for Amazon sellers, and which in the OSS return in Amazon and OSS.

How do you find such sales in the Amazon report?

According to Amazon, the VAT Transactions Report (AVTR) contains all taxable transactions on the European marketplaces and in Amazon's logistics network. You find it in Seller Central under Reports, Fulfilment by Amazon, Taxes, Amazon VAT Transactions Report; one report covers at most 93 consecutive days. The columns DEPARTURE_COUNTRY and ARRIVAL_COUNTRY show the country of departure and arrival of a transaction. If the VAT calculation service is not activated, the report shows only the gross price and you calculate the tax yourself.

In its developer documentation, Amazon names fields on tax collection for its tax reports, such as Tax Reporting Scheme and Tax Collection Responsibility. It does not describe there which values these fields take or what they mean in an individual case. For more information Amazon refers to its page "Definitions of the Amazon VAT Transactions Report"; do not guess the meaning. More on the columns is in Amazon VAT report columns explained.

Is a holdback on your payout the same thing?

No. Whether Amazon holds back part of your balance says nothing about who owes the tax; that follows from the law alone. How payout, revenue and profit differ is in Amazon payouts and tax.

Common mistakes

Assuming Amazon pays everything. Outside the cases in the law you are the tax debtor, unless your business customer owes the tax by exception (section 13b UStG).
Deleting a report row on a hunch. Which row does not belong to your sales is decided by the law.
Booking a payout holdback as a tax payment without checking. Who owes the tax follows from the law, not from the payout.
Guessing the report fields. Check the meaning instead of guessing; if in doubt, ask your tax adviser.

How VAT GPT helps

VAT GPT is the tax software for Amazon and eBay sellers in Germany: your OSS return first, then every other tax you owe, calculated and filed in one place.

You upload the Amazon CSV, and VAT GPT sorts the sales rows by tax scheme and country (Germany or EU/OSS).
Rows of the scheme UNION-OSS count as OSS, REGULAR as Germany or, in another country, as VAT there, and CH-VOEC and UK-VOEC-IMPORT as sales outside the EU.

With VAT GPT Pro you send the VAT return through ELSTER and the OSS return to the BZSt. There is Free, Go (30 days free with all Pro features) and Pro (€49 per month or €444 per year, including VAT). Try for Free Now

Frequently asked questions

Does Amazon pay my VAT? Under the German VAT Act, only in the cases in which the marketplace counts as the supplier (section 3(3a) UStG). Otherwise you are responsible. Sales to countries outside the EU follow those countries' own law.

Does this apply if I am based in Germany? The first case requires a seller outside the EU; the second concerns imported goods up to 150 euros intrinsic value.

Is a payout holdback VAT? The payout alone does not show it; who owes the tax follows from the law (section 3(3a) UStG).

How do I see in the report who collects the tax? The report has the field Tax Collection Responsibility for this; Amazon's developer documentation does not describe its values. Do not guess; if in doubt, ask your tax adviser.

Do I have to show such sales in my VAT return? That depends on who counts as the supplier. If in doubt, ask your tax adviser.