With its letter dated 23 January 2015 the German Ministry of Finance explained its position regarding the evidence for VAT zero-rated exports according to Sec. 6 German VAT Act. Within this letter the German Ministry of Finance named explicitly alternative evidences (thus the old “Ausgangsvermerk” is not the only way of proving the export anymore) which proof the export supply sufficiently. This is especially applicable for:

• Export notice due to a monthly multiple application according to Art 285a Para. 1a ZK-DVO (European Customs Code – Executive Order),
• Export notice due to retroactive export declaration in emergency procedures according to Art. 787 Para. 2 ZK-DVO,
• Export notice due to retroactive export declaration according to Art. 895 ZK-DVO and
• Export notice due to a retroactive export declaration subject to prior total or partial incorrect export declaration.

The letter of the German Ministry of Finance is applicable for all pending cases. It is recommendable to verify whether this means simplifications or changes for your company occur or not.

In case of any further questions in this connection or in connection with any other questions regarding VAT, please do not hesitate to contact us.