Comments on the current letter of the Federal Ministry of Finance on intra-Community supplies – Part 7

In this multi-part series of articles, we would like to present how the tax authorities comment on the changes from 01.01.2020 in the context of the so-called “quick fixes”. The principles apply to all deliveries made after 31.12.2019.

We hope you enjoy reading!

BMF letter dated October 9, 2020, III C 3 – S 7140/19/10002

The BMF letter can be found at:

Attention NEW:

In addition to this, the tax authorities have issued a further letter dated 28.10.2020.

BMF letter dated October 28, 2020, III C 5 – S 7427-d/19/10001:001

The BMF letter can be found at:

Alternatives to the BZSt

postal qualified confirmation.

The qualified confirmation informs whether the details of the company name (including legal form), company location, zip code and street correspond to the data registered in the entrepreneur file of the respective EU member state.

The query made in the Internet form of the BZSt, is usually subsequently requested by mail from the Federal Central Tax Office. The entrepreneur then receives a few days later the requests by mail. He must then check this and file and keep it accordingly.

In the new USt-Anwendungserlass, it will be stated in the future that in the case of inquiries regarding individual USt-IdNr. the proof of the performed qualified confirmation inquiry must be kept by keeping the printout or the transfer of the result transmitted by the BZSt in a generally common format or as a screenshot into the company’s system. The word “may” is replaced here by the word “is” in each case!

For a few queries, this is certainly possible. But for mass queries, this is no longer feasible manually or analogously. Here the entrepreneur should or must look for software-based support.

1. Interface from BZSt – Confirmation of foreign VAT identification numbers via XML-RPC interface

As a supplement to the confirmation procedure via the Internet form, the Federal Central Tax Office (BZSt) offers an alternative that is particularly aimed at companies with many confirmation requests.

Using the so-called XML-RPC interface, companies are given the option of integrating the verification of foreign VAT registration numbers (VAT registration numbers) into their own software systems and automatically retrieving the VAT registration numbers.

The integration of the XML-RPC interface must be done by the company itself and requires appropriate programming skills. However, this effort can also be saved by using software. Among other things, the VAT ID checker from Optimus Software GmbH offers this convenience.

2. Advantage of the interface

The advantage of the interface is that, in contrast to the individual query via the Internet form, it is not necessary to manually enter the entrepreneur data to be checked. The electronic answer (data record) transmitted by the BZSt can be integrated into the own system and evaluated. In these cases, the proof of a carried out qualified request of a VAT registration number – deviating from the principle of a qualified official confirmation notice – can be carried out via the data record received from the BZSt.

In the new USt-Anwendungserlass it states in the future that in cases where the interface is used and is integrated into the company, it is necessary to provide proof of a performed qualified request of a USt-IdNr. via the data record received from the BZSt ! (Section 18e.1 para. 2 sentences 4-5). Here, too, the word “may” is replaced by the word “is” in each case!

The VAT ID auditor of Optimus Software GmbH can handle this, too.

3. Advantages of software-based support

  • Mass queries are easy and quick to manage
  • You can check the entire inventory unproblematically, quickly and in short time intervals
  • Results are available immediately
  • Records can be easily stored and archived in the company’s own system in an audit-proof manner
  • Paper is no longer required
  • The postal return no longer needs to be monitored. It therefore saves costs
  • The tax authorities consider it mandatory to keep the proof in the received data record when using the interface and no longer in the postal qualified confirmation


The content reproduced is for general information purposes. All contributions are compiled to the best of our knowledge. These are neither intended nor suitable to replace an individual consultation by expert persons, taking into account the specific circumstances of each individual case. No liability can be assumed for their content. Please contact your tax advisor for your individual case.