Small-amount invoices in Germany (§ 33 UStDV): when the buyer's address can be left out

What a small-amount invoice is

§ 33 sentence 1 UStDV (German) simplifies invoices with a total of up to €250: the recipient's name and address may be left out. What remains is a reduced list of required details: the full name and address of the supplier, the issue date, the quantity and type of the supply, and the net amount and tax as one total together with the applicable VAT rate (or a note on a tax exemption).

For online shops this is more than a formality. Payment data from a payment provider often has no complete billing address, only a name and an email. Under €250 that is not a problem: the sale gets a valid document with no recipient block at all. The buyer loses nothing, because § 35(1) UStDV (German) still allows input VAT deduction from a small-amount invoice.

When § 33 does not apply

Three groups of cases are excluded whatever the amount (§ 33 sentence 3 UStDV, German):

• Distance sales under § 3c UStG, meaning the typical EU B2C sales reported through the OSS scheme (One-Stop Shop).
• Intra-Community supplies (§ 6a UStG): the tax exemption requires the buyer to use a valid VAT ID (§ 6a(1) no. 4 UStG, German), and the invoice must show both VAT IDs (§ 14a(3) UStG, German).
• Reverse charge (§ 13b UStG): the recipient owes the tax (§ 13b(5) UStG, German) and therefore has to be named on the invoice.

Then there is the limit itself: from €250.01 gross, every invoice needs the recipient's full details under § 14(4) sentence 1 no. 1 UStG (German). A document without an address is then formally defective. The customer cannot reclaim input VAT from it, because that requires an invoice under §§ 14 and 14a UStG (§ 15(1) sentence 1 no. 1 sentence 2 UStG, German).

Why "invoice by card country" is not enough

Some tools turn every payment into a PDF invoice automatically and set the VAT by the country of the card used. That sounds like automation, but it runs straight into the exclusion. If you split VAT by the buyer's country, you are treating the sale as a distance sale under § 3c UStG, and exactly those sales are excluded from the small-amount simplification. An invoice for such a sale without the recipient's full address does not meet § 14(4) UStG.

The consequence: a system that creates address-less documents for OSS sales does not produce proper invoices. The only clean approach is to decide case by case. A domestic sale up to €250 gets a small-amount invoice; everything else gets an invoice with complete data, or no invoice until the data is there.

Small amounts and the e-invoicing mandate

The e-invoicing mandate for domestic B2B sales explicitly exempts small-amount invoices: up to €250, an invoice may always be sent as an "other invoice" (sonstige Rechnung), for example as a PDF or on paper (§ 33 sentence 4 UStDV, German). For the PDF you need the recipient's consent, which requires no particular form (section 14.1(7) UStAE, German). This fits together, because a structured e-invoice under EN 16931 technically requires a buyer block. A recipient that § 33 does not ask for would have to be invented there. A clean system therefore creates a reduced document for the small-amount case on purpose, instead of an XML file with a made-up recipient. And B2C sales are not covered by the e-invoicing mandate anyway.

Issuing a full invoice later

If a business customer later asks for an invoice with their address, Rechnungskit does not reissue the small-amount invoice through a cancellation (Storno). It adds the recipient's details under the original invoice number. This follows the rules for correcting an invoice, where a separate document refers specifically and unambiguously to the original invoice (§ 31(5) UStDV, German; more under changing the billing address). The sale stays booked exactly once, and no second invoice for the same supply comes into existence from which the stated tax could be owed a second time (section 14c.1(4) UStAE, German). If you are unsure whether this route fits your case, check with your tax advisor (Steuerberater).

How Rechnungskit handles it

Rechnungskit checks every document individually against § 33: the gross limit, § 3c, § 6a and § 13b. If recipient data is missing and the check passes, it creates a valid small-amount document automatically, archived tamper-proof, with the reason logged per document. If the check fails (over €250, an OSS case, reverse charge), no defective document is created. Instead, the payment shows up as a task under Payments until the data is complete. If you only ever want to issue full invoices, switch off the small-amount fallback in the document rules; Rechnungskit then always asks for the full address. Adding recipient details later works directly from the document view, under the original number.