The German Federal Ministry of Finance issued supplementary guidance on 29 April 2026 clarifying VAT treatment of intermediary services in multi-purpose voucher distribution chains, with immediate application to all open cases.
Technical Changes
The ministry updated section 3.17 para. 12 of the Administrative VAT Guidelines (UStAE) to specify that intermediaries issuing vouchers in their own name must determine taxable amounts based on the difference between voucher face value and purchase price, not actual resale margins. For multi-tier chains where no remuneration agreements exist and intermediaries lack knowledge of final customer prices, the taxable base uses the voucher's face value rather than the actual onward sale price.
Under the new approach, if taxable person A sells a EUR 100 face value voucher to intermediary B for EUR 90, who resells to intermediary C for EUR 95, who sells to the final customer for EUR 100, B's gross remuneration becomes EUR 10 (face value minus purchase price) rather than EUR 5 (actual margin), with VAT extracted from the higher amount.
Context
The guidance addresses uncertainty in voucher distribution VAT treatment that has existed since 2020 rules established intermediary services as taxable. The clarification may create retrospective VAT liabilities for intermediaries while generating corresponding input VAT opportunities for upstream suppliers, fundamentally altering the economics of voucher distribution chains where formal remuneration agreements are absent.
