VAT warehouse

The repeal came through Article 26 of the Annual Tax Act 2024 of 2 December 2024, effective 1 January 2026. The statute now carries only the word weggefallen at that point. New entries into an approved warehouse are therefore impossible, and the tax authority has withdrawn the related administrative guidance.

Spirits never came within the rule. Annex 1 to section 4 no. 4a UStG listed the eligible goods exhaustively: 27 positions from potatoes through coffee and mineral oils to copper, nickel and tin. Ethyl alcohol and spirits were absent, and goods put up for retail supply were excluded in any case. Bottled goods could therefore never sit in a VAT warehouse.

For the transitional period: supplies that were exempt before 1 January 2026 stay exempt until the goods are removed (section 27 (40a) UStG). At the end of 30 December 2029 all goods not removed by then count as removed. The last supply before that becomes taxable, and the person removing the goods owes the VAT.

The most common mistake is confusing it with the tax warehouse under the Alcohol Duty Act. In everyday use both are called a warehouse and both defer a tax, yet they concern different taxes, different authorities and different goods. The repeal in the VAT Act does not touch an excise authorisation.

Second, with existing stock it often stays unclear who counts as the person removing the goods. That is whoever holds the power of disposal at that moment, and they need a German VAT identification number. The warehouse keeper becomes jointly and severally liable where that number is not recorded, or recorded incorrectly. Settle these roles in writing before the first removal.