Gift card accounting for online shops in Germany: single-purpose vs. multi-purpose vouchers

Single-purpose or multi-purpose: § 3 UStG decides

For vouchers issued after December 31, 2018, German VAT law distinguishes two kinds of voucher (§ 3(13) to (15) UStG, § 27(23) UStG), and the distinction decides when the tax arises:

Single-purpose voucher (Einzweck-Gutschein, § 3(14) UStG): the place of supply and the VAT due are already fixed at the time of sale, for example a gift card that is only valid for goods with a single VAT rate in Germany. VAT arises as soon as the card is sold.

Multi-purpose voucher (Mehrzweck-Gutschein, § 3(15) UStG): at the time of sale it is still open what the card will be redeemed for. That is typical for shop gift cards valid across the whole range with mixed VAT rates (in a coffee shop: beans at 7 percent, equipment at 19 percent). VAT only arises on redemption.

Most online shop gift cards are multi-purpose vouchers. Standard invoicing tools still treat them as single-purpose or ignore them altogether.

For a voucher to be single-purpose, two things must both be fixed when it is issued: the place of supply (and with it the member state entitled to the tax) and the VAT rate due. If even one of them is missing, it is a multi-purpose voucher. This matrix shows the four typical cases:

Why SaaS and digital credits are almost always multi-purpose

Software subscriptions often have just one VAT rate: 19 percent (§ 12(1) UStG). The reduced 7 percent rate for electronic books and newspapers (§ 12(2) no. 14 UStG) does not apply to software. The VAT rate condition is usually met, so many people assume a SaaS credit is a single-purpose voucher. The catch is the second condition, the place of supply. For electronic services to consumers, the place of supply is where the customer lives (§ 3a(5) UStG). Whoever redeems the credit later may live in a different EU country than at the time of purchase, or the credit is given away as a gift. So when it is issued, it is not fixed which country may tax it, and a credit that can be redeemed across borders is regularly a multi-purpose voucher.

One point for context: this follows from the place-of-supply rule, not from the OSS procedure. OSS (the One-Stop-Shop) is only the channel for reporting and paying cross-border B2C sales and does not change how a voucher is classified. A single-purpose voucher is possible for SaaS too, but only if the place is really fixed when it is issued. In our assessment that requires a hard tie to one country: a Germany-only store, a credit firmly bound to a German customer account, and terms of use that rule out redemption from other countries. Credits that can be gifted freely and are not tied to an account are multi-purpose. Whether a country tie holds up in your case is something to settle with your tax advisor (Steuerkanzlei). So SaaS is not the "easier" single-purpose case; it just fails at a different condition than a shop selling goods.

What has to happen at sale and at redemption

When a multi-purpose gift card is sold, a liability for the card value arises, with no revenue and no VAT (§ 3(15) UStG), and the receipt for the buyer shows no tax accordingly. On redemption, the liability is released, the revenue arises at the VAT rate of the products actually bought, and the invoice to the customer redeeming the card is an ordinary, complete invoice.

In between sits a third task almost everyone forgets: the outstanding gift card volume has to be traceable as a liability at any time, per card, with remaining value and age, for the balance sheet and tax audits.

How Rechnungskit handles gift cards

Rechnungskit keeps its own gift card register. A sale books the liability, partial redemptions reduce the remaining value, the redemption creates the correct invoice at the real VAT rates, and the outstanding volume is available as a report and in the DATEV export. Gift card data comes straight from your shop, for example from Shopify gift cards. How gift cards, discount codes and store credit differ for tax purposes in Shopify is covered in the guide on Shopify gift cards.

The page on deferred revenue explains how gift cards differ from pro rata deferral.

Important: Shopify store credit from a return or a goodwill gesture is not the same as a gift card you sold. How Rechnungskit keeps the correction document, the credit liability and the later redemption apart is shown on the solution page Booking Shopify store credit correctly.