Invoicing Non-EU Customers from Germany 2026: Third-Country Invoice Rules for GmbH and Freelancers

US agencies, UK enterprises, Swiss family businesses, Australian startups — if you run a GmbH, UG or freelance business in Germany with customers outside the EU, you need to issue a third-country invoice. The rules are different from German or EU invoicing, and mistakes either cost you input VAT or trigger questions from the tax office. Here's how to do it right.

What is a third-country invoice?

A third-country invoice is an invoice to a customer based outside the European Union — the US, UK, Switzerland, Norway, Australia, or any other non-EU state. The rules for VAT and the required fields are different from invoices inside Germany or the EU. For SaaS providers, agencies, consultants and IT freelancers in Germany, this is daily business.

Third country vs. EU: the key difference

Inside the EU, you either apply reverse charge or document an intra-community supply — both require a valid EU VAT ID from the customer. In a third country, neither applies. Most B2B services are simply not subject to German VAT (§ 3a UStG for services, § 6 UStG for goods exports). The result: no German VAT on the invoice, but you need different evidence for your records.

When German VAT does not apply

• [@portabletext/react] Unknown block type "span", specify a component for it in the `components.types` propplace of supply is the customer's country, no German VAT
• [@portabletext/react] Unknown block type "span", specify a component for it in the `components.types` propVAT-exempt under § 6 UStG, but you need an export confirmation
• [@portabletext/react] Unknown block type "span", specify a component for it in the `components.types` propgenerally not subject to German VAT
• [@portabletext/react] Unknown block type "span", specify a component for it in the `components.types` propspecial rules apply, especially for digital services

Required fields on a third-country invoice

Most of the standard required invoice fields still apply, with two specifics for non-EU sales:

• Full names and addresses of both seller and non-EU customer
• Your German tax number (Steuernummer) or VAT ID (USt-IdNr.)
• Sequential invoice number, invoice date, service or delivery date
• Description of the service or goods, net amount (no German VAT line)
• [@portabletext/react] Unknown block type "span", specify a component for it in the `components.types` propfor services "Not subject to German VAT"; for goods exports "VAT-exempt export under § 6 UStG"

B2B vs. B2C: caution with private non-EU customers

Non-EU B2B is usually straightforward: no German VAT, clear note on the invoice. B2C is trickier. For digital services to private customers (SaaS, e-books, online courses), local tax rules in the customer's country often apply. If you sell regularly to US consumers, US sales tax may eventually become relevant in some states. For EU consumers, the OSS procedure covers it; for non-EU consumers it does not.

Foreign currency: what to know

You can invoice in any currency — EUR, USD, GBP, CHF. But your books must be in EUR. Convert using the official exchange rate published by the German Federal Ministry of Finance or the ECB rate on the day of supply. Currency differences between invoice and payment are booked as other operating income or expense, not as a sales adjustment.

Bookkeeping: how to record third-country sales

In SKR03 or SKR04, third-country sales have dedicated accounts: SKR03 8120 "VAT-exempt sales § 4 No. 1a UStG" for exports, or specific accounts for non-taxable services. On your VAT return, third-country exports usually go to line 41 (VAT-exempt exports). You still keep your input VAT deduction on your own incoming invoices.

How Norman handles third-country invoices

With Norman you create a third-country invoice in one click — with the correct VAT note, foreign-currency conversion and the right account in your chart of accounts. The software detects the third country from the customer address and adds the right footer text automatically. The AI bookkeeping then posts the entry to the right SKR account so your VAT return is clean.

Conclusion

Third-country invoicing isn't complicated once you know the basics: no German VAT for non-EU B2B, a clear VAT note on the invoice, clean records for your books. Get the required fields right, convert foreign currency at the official rate, and book to the correct account. With the right software, the compliance side handles itself — and you keep selling globally.