§18e UStG
The German law requiring sellers making VAT-free intra-EU supplies to obtain a qualified confirmation from BZSt that the foreign customer's VAT number and company details match.
What it is
§18e of the Umsatzsteuergesetz (UStG, Germany's VAT Act) entitles a German seller to obtain a qualified confirmation from the Bundeszentralamt für Steuern (BZSt) that a foreign customer's VAT number is valid and that the registered name and address details on file match the information shown on the invoice.
Where you meet it
You meet §18e UStG whenever a German business makes a VAT-free intra-EU supply to a buyer in another EU member state and wants to protect its legal position in a tax audit. The zero-rate applies only if the buyer is a VAT-registered business. If the buyer's number turns out to be invalid, or the registered details don't match the invoice, the German seller can lose the zero-rate and become liable for the output VAT.
A "simple" VIES check (querying whether the number is currently valid) is the baseline requirement. The §18e qualified confirmation goes further: it asks BZSt to compare the buyer's VAT number against four additional fields.
What BZSt matches
BZSt returns a match code for each of the following fields, compared between what you supplied and what is on the BZSt/VIES register:
| Field | Match codes |
|---|---|
| Company name | A (match), B (similar), C (no match), D (not requested) |
| Street | A / B / C / D |
| Postcode | A / B / C / D |
| Town | A / B / C / D |
A result of A or B on all fields is considered a positive qualified confirmation. A C result on any field means the supplied detail does not match the register and you should verify the invoice details directly with the buyer.
Why it matters
A positive §18e qualified confirmation shifts the burden of proof to the tax authority. If you relied on the confirmation in good faith and the buyer's VAT number was fraudulently issued or the details were misrepresented, the German tax authority cannot simply claw back the zero-rate from you. Without the confirmation, the seller bears the full risk if the buyer's status turns out to be wrong. This protection is particularly relevant where MTIC fraud is a risk in the supply chain.