Meaning of Recapitulative Statement

If you sell goods and services in other EU countries, it is not only done with the advance VAT return. You will also need to create a EU Sales List. But what is the EU sales list? In addition, who has to create the report and when does it have to be submitted? We’ll tell you all this and more in our article.

EU sales list – what is it?

The summary report (ZM) gives the Federal Central Tax Office an overview of the goods and services sold in other EU countries – listed according to the recipient’s sales tax identification number (USt-IdNr.).

Typically, you will include sales tax for your products or services on your invoices . You then pay the tax levied to the tax office. Your actual sales tax payable will be determined via the sales tax return. For this purpose, the input tax that you yourself paid for purchases is simply deducted from the sales tax collected .

Products and services that are sold to companies in other EU countries , on the other hand, are sold without sales tax. This means that no sales tax may be shown on the invoice . However, this does not mean that the deliveries and services are exempt from sales tax. It’s just that you don’t have to collect sales tax and pay it to the tax office. Rather, the customer has to pay the tax burden in their own country.

This is regulated by the so-called “ reverse charge procedure ”: It is not the seller (service provider) who pays the sales tax but the customer (service recipient). In the country in which the customer (the company) is based.

In order for the customer to know that the payment burden is being transferred to him, the note “Tax liability of the service recipient” must always be noted on the invoice to other EU countries .

Attention: The reserve charge procedure only applies to corporate customers, not to private individuals. Because private individuals cannot have a VAT ID number. apply for and therefore do not owe the sales tax.

With the recapitulative statement and the VAT ID no. the delivered goods and services can be checked within the EU. And the member states can check whether the customer pays the sales tax due for the turnover generated in the recipient country (place of performance). For this, the data from the ZM is automatically exchanged between the states and compared with the data of the customer in his tax return .

Note: If you have bought products or services from outside the EU, you do not have to state these in the EU sales list.

What is reported?

The recapitulative statement must be created for the following sales:

  • Intra-Community deliveries (products supplied commercially between Member States)
  • Triangular intra-community transactions
  • Non-taxable intra-community services

This means that all products and services that are sold to companies in other EU countries and for which no sales tax is levied in Germany must be listed in the recapitulative statement. This ensures that sales tax is also offset between EU countries.

Who has to make a recapitulative statement?

The following applies to the recapitulative statement : Anyone who is subject to VAT in Germany and who sells products or services in other EU countries must create this . This includes both freelancers , foresters, farmers and traders .

Small business owners are an exception : Since small business owners do not charge sales tax, they are not allowed to show this on their invoices and do not have to pay sales tax to the tax office. This means that you do not have to submit a recapitulative statement. As a small business owner, you can also use a template for an invoice without sales tax .

How do I create a recapitulative statement?

The recapitulative statement can only be sent electronically . This is very easy via the Elster online portal or the BZStOnline portal .

To do this, you have to register with the respective portal in order to receive authentication. This is a prerequisite for sending the EU sales list online.

The summary report via ElsterOnline

If you create the report via the ElsterOnline portal, it works like this:

  1. Enter your sales tax identification number
  2. Select the reporting period (the year and then the month or quarter)
  3. Now click on the “Next” button
  4. Enter your personal data (company name, address and telephone number)
  5. Then click on “Next”
  6. Now you have to enter the VAT ID number of the customer supplied as well as the sales generated by him.
  7. If you have supplied several customers, you can add more lines. As in the first line, you enter the VAT ID number. and the associated sales.

Once you have entered and checked all the data, you can send the report directly.
The report is submitted together with the advance VAT return. The details of both reports must match: Because in the pre-notification you must already specify the intra-community deliveries, services and triangular transactions and these will be compared with the ZM.

What information should be included in the EU sales list?

So that the products and services can be assigned directly to the individual recipient, the recapitulative report not only has to include your VAT ID number. but also those of the recipient.

To do this, you should always check the recipient’s identification number . Because if this is wrong, you have to pay the sales tax. It doesn’t help if you say that you believed the customer and the accuracy of his information. Therefore, you should always check the VAT ID . And if the number seems wrong, contact the customer again if in doubt.

This means that the following information must not be missing from the EU sales list:

  • Your personal data (VAT number, name, address)
  • The customer’s sales tax identification number
  • For each recipient of the service, the invoice amount (= sum of the assessment base)
  • Type of turnover

What happens if I entered incorrect information or forgot?

Even when creating a recapitulative statement, errors can occur or information can be forgotten. In this case, there is a special obligation to make corrections .

You must adjust the EU sales list within one month . The monthly period begins at the point in time at which the error is recognized.

Note: The period of one month refers to the receipt of the corrected ZM by the BZSt.

When does the recapitulative statement have to be submitted?

The recapitulative statement must be submitted together with the advance VAT return. As with pre-registration, the reporting periods depend on sales .

1. Deliveries of goods

  • Monthly notification: by the 25th day of the following month at the latest. For sales over 50,000 euros.
  • Quarterly reporting: by the 25th day of the month after the end of the quarter at the latest. For sales that do not exceed 50,000 euros in the quarter.

2. Services

  • Quarterly reporting: by the 25th day after the end of the quarter at the latest.

If you have not sold any deliveries or services to other EU countries in the respective reporting period, you do not have to submit a ZM.

What if I don’t submit the report? So what?

If you do not create a recapitulative statement, this is considered an offense. First you will receive a letter from your tax office asking you to submit the ZM. This threatens a late penalty of up to 2,500 euros and a fine of up to 5,000 euros.

If you do not comply with the request, you will have to expect a fine. This can be up to 25,000 euros. And even if you pay this, you can’t avoid the EU sales list. Because this can be forced. So, one way or another, you need to create and submit the report.


The recapitulative statement is therefore mandatory for you if you sell products or services in other EU countries. The structure is structured according to the respective sales tax ID of your customers. The ZM must be submitted electronically, i.e. the electronic transmission takes place via the ELSTER form. In the context of the sales tax law, mandatory information and the reporting period are specified.

Recapitulative Statement