OSS return for a VAT group (Organschaft) in Germany: who registers and who files?

In a German VAT group (Organschaft), the controlling company, called the Organträger, applies for OSS participation under its own VAT identification number. That is what the BZSt states. The subsidiary does not file for itself; its EU sales to consumers belong in the controlling company's OSS return.

Last updated: 29 October 2026

In short

  • Who registers: The controlling company (Organträger), with its VAT ID. It is stated on the BZSt's OSS page.
  • Why: The subsidiary does not carry on its activity independently (§ 2 (2) no. 2 UStG); in Germany the controlling company and the subsidiary are treated as one business.
  • Deadline and channel: The return goes to the BZSt every quarter within one month after the quarter ends (§ 18j (4) UStG), through the BZStOnline portal.

What is an Organschaft, and why does only one company file?

An Organschaft exists when a legal entity is, judged by the overall picture of the actual circumstances, integrated financially, economically and organisationally into the business of the controlling company (§ 2 (2) no. 2 UStG). The subsidiary then does not carry on its commercial activity independently. The business parts located in Germany are treated as one business.

The OSS is a procedure of the entrepreneur. Whoever applies it submits a return after each quarter (§ 18j (4) UStG). In a VAT group that entrepreneur is the controlling company. For the registration the BZSt is explicit: for VAT groups, participation in the special scheme must be applied for by the controlling company under its VAT identification number.

What this means for you: As the controlling company you register once for the whole group, not per company.

How do you proceed as the controlling company?

  1. Clarify the Organschaft: Check with your tax adviser whether financial, economic and organisational integration exists. The overall picture decides (§ 2 (2) no. 2 UStG).
  2. Register: You apply for participation in the BZStOnline portal and give your own VAT ID. The application is electronic.
  3. Mind the start: Registration generally starts on the first day of the calendar quarter after the application (BZSt). The notification must be made before the start of the tax period (§ 18j (1) UStG).
  4. Bring all sales together: The return covers the EU sales to consumers of the whole group in Germany.
  5. Report and pay each quarter: The return is due within one month after the quarter; the tax is due on the last day of the following month (§ 18j (4) UStG).

What this means for you: Registration, return and payment go through one entity, the controlling company.

What about a subsidiary that sells on Amazon or eBay itself?

If the subsidiary sells through its own seller account to consumers in other EU countries, the sale legally belongs to the controlling company's business, because the subsidiary does not act independently (§ 2 (2) no. 2 UStG). For the OSS return this means: the subsidiary's country lines are merged with those of the controlling company in one return.

The BZSt names the controlling company's application as the route. The BZSt page does not say that the subsidiary can also register itself in addition. So do not register the companies twice; clarify the case in advance with the BZSt or your tax adviser.

What this means for you: Collect the marketplace reports of all companies in the group before you prepare the quarterly return.

What happens with a controlling company abroad?

If the controlling company has its management abroad, the economically most significant business part in Germany counts as the entrepreneur (§ 2 (2) no. 2 sentence 4 UStG). The effects of the Organschaft are also limited to internal supplies between the business parts located in Germany (sentence 2).

Who applies when the controlling company is based abroad has to be checked in the individual case. Neither the law nor the BZSt page answers it for every setup. Take professional advice before you register.

What this means for you: If the controlling company is abroad, clarify responsibility before the application.

Which mistakes happen often?

  • Registering each company separately. The BZSt provides for the controlling company's application under its VAT ID.
  • Entering the wrong VAT ID. The one meant is that of the controlling company, not the subsidiary's.
  • Forgetting the subsidiary's reports. Its sales belong in the same return.
  • Applying too late. Participation starts only in the following quarter.
  • Missing the quarterly deadline. It ends on the last day of the following month (§ 18j (4) UStG).

What this means for you: Before each quarterly return, check that all companies of the group are in your data.

How does VAT GPT help here?

VAT GPT is the tax software for online sellers, self-employed people and small businesses in Germany – OSS return first, then VAT, EÜR, trade tax and income tax, calculated and filed in one place. VAT GPT works out the OSS return from your reports and invoices with the method "Upload – check – send":

  1. Upload: You upload the Amazon or eBay CSV reports and invoices. The AI reads amounts, countries and tax rates.
  2. Check: VAT GPT calculates the OSS return for all EU countries. You check the country lines and confirm.
  3. Send: With VAT GPT Pro the OSS return goes directly to the BZSt. You register for the OSS yourself in the BZStOnline portal.

How VAT GPT maps several companies into one return is not covered in this guide; clarify it before you use it. Plans are Free, Go (30 days free with all Pro features) and Pro. Try it free

What this means for you: The reports become the return in three steps.

Frequently asked questions

Who files the OSS return in a VAT group? The controlling company. The BZSt writes that it applies for participation under its VAT ID.

Does the subsidiary need its own OSS return? The BZSt page names only the controlling company's application. It does not provide for a registration of the subsidiary beside it; clarify unclear cases with the BZSt.

Which VAT ID goes into the OSS application? The controlling company's.

What is the deadline? Within one month after each quarter, like any OSS return (§ 18j (4) UStG). All dates are in How often must I file the OSS return?.

Does it matter whether the company is a GmbH & Co. KG or a UG? The question is not the legal form but whether the integration under § 2 (2) no. 2 UStG exists. Your tax adviser clarifies that.

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No tax advice: the content does not replace individual advice.

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