Annual VAT return as a small business in Germany: where do you enter your sales?
As a small business (Kleinunternehmer) you generally do not have to file an annual VAT return. The ELSTER guide says small businesses are exempt from submitting VAT returns. That does not cover the cases of section 18 (4a) UStG, and the duty remains if the tax office asks you to file. If you have to file or were asked to, you enter your exempt sales in line 48 of the 2025 ELSTER form.
Last updated: 26 October 2026
The essentials in brief
- Basic rule: for tax periods from 2024, small businesses are generally exempt from the annual VAT return (Bavarian State Office for Taxes).
- Exceptions: the cases of section 18 (4a) UStG and a request from the tax office (section 149 (1) sentence 2 AO).
- Line 48: here a small business enters its exempt sales under section 19 (1) UStG, but only if obliged to file or asked to.
- Line 16: date of the change to standard taxation, only in certain cases.
- Limits: 25,000 euros in the previous year, 100,000 euros in the current year; in the founding year 25,000 euros applies.
When must a small business file a return?
According to the Bavarian State Office for Taxes, small businesses are generally exempt from the annual VAT return for tax periods from 2024. Anyone who falls under the exceptions of section 18 (4a) UStG or is asked to file remains obliged to file. Under section 18 (4a) UStG and section 149 (1) sentence 2 AO these are the cases:
- you owe tax on an intra-Community acquisition (section 1 (1) no. 5 UStG),
- you owe the VAT as recipient of a supply or service (section 13b (5) UStG),
- you owe the VAT as final customer in an intra-Community triangular transaction (section 25b (2) UStG),
- you are a vehicle supplier (section 2a UStG),
- the tax office asks you to file (section 149 (1) sentence 2 AO).
According to the ELSTER guide, section 18 (4a) UStG covers, for example, intra-Community acquisitions and services received for which a small business owes the tax as recipient (section 13b UStG). By statute, section 19 (1) sentence 2 UStG takes small businesses out of the filing duties of section 18 (1) to (4) UStG; section 149 (1) sentence 2 AO and section 18 (4a) UStG remain unaffected.
Line 48: exempt sales as a small business
In the ELSTER form for the 2025 VAT return you give details in line 48 only if you made exempt sales under section 19 (1) UStG as a small business and are obliged to file under section 18 (4a) UStG or the tax office has asked you to file. The sales are exempt in Germany under section 19 (1) UStG as far as total turnover did not exceed 25,000 euros in the previous calendar year and 100,000 euros in the current calendar year, and you did not waive the exemption.
The sale that takes you over the 100,000 euro limit in the current year is already no longer exempt but subject to standard taxation; it does not belong in line 48. If you started your business during the year, this applies from the sale that exceeds 25,000 euros.
Line 16: date of change to standard taxation
The ELSTER guide has you enter the date of the change from the small-business rule to standard taxation in line 16 only in these cases:
- You founded your business in the current year and total turnover exceeded 25,000 euros: the date of the sale that crossed the limit.
- Total turnover in the current year exceeded 100,000 euros: the date of the sale that crossed the limit.
- You waive the small-business rule from the start of the year (section 19 (3) UStG): for 2025 you enter 1 January 2025. According to the ELSTER guide you can declare the waiver to the tax office until the last day of February 2027; you are bound by it for at least five calendar years.
If your total turnover in the previous year exceeded 25,000 euros, standard taxation applies from 1 January of the current year. In that case you enter no date in line 16. More on the change: switching from the small-business rule to standard VAT and small business rule 2026: limits.
What applies to input VAT?
While the small-business rule applies you are, according to the ELSTER guide, not entitled to deduct input VAT under section 15 UStG. That also applies to tax amounts you owe as a small business.
Common mistakes
- Filing the annual VAT return automatically. First check whether an exception under section 18 (4a) UStG applies or the tax office has asked you to file.
- Filling in line 48 although there is no duty. The ELSTER guide names entries in line 48 only for those obliged or asked to file.
- Recording the sale above the limit as exempt. The sale that crosses the limit is already subject to standard taxation.
- Overlooking the founding year. The limit there is 25,000 euros.
- Overlooking the commitment after a waiver. It lasts at least five calendar years.
How it works with VAT GPT
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- Upload documents: the AI reads invoice date, amounts, currency and country. You check and confirm the values.
- Check the result: VAT GPT prepares advance returns, annual returns, EÜR, trade tax and income tax return.
- Send: with VAT GPT Pro via ELSTER directly to the tax office.
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What VAT GPT does not do
- VAT GPT is not tax advice, for example on whether you must file as a small business.
- The AI reads date, amounts, currency and country; whether an exception under section 18 (4a) UStG applies is for you to check.
What does VAT GPT cost?
Free (basic features, free of charge), Go (30 days free with all Pro features), Pro €49 per month or €444 per year, each including VAT.
Frequently asked questions
Must a small business file an annual VAT return? Generally no, for tax periods from 2024. Exceptions are section 18 (4a) UStG and a request from the tax office.
Where do my small-business sales go on the form? In line 48, if you are obliged to file or were asked to.
Which limits apply? 25,000 euros in the previous year and 100,000 euros in the current year (section 19 (1) UStG); in the founding year 25,000 euros.
What do I enter in line 16? The date of the change to standard taxation, only in the cases above.
Until when can I waive the small-business rule for 2025? According to the ELSTER guide, until the last day of February 2027.
May a small business deduct input VAT? No, while the rule applies.
Further reading
- Small business rule 2026: limits
- Switching from the small-business rule to standard VAT
- Advance VAT return as a small business
- Annual VAT return in Germany
- Annual VAT return 2025: deadline
Not tax advice: the content does not replace individual advice.