1. Germany Broadens Evidence Requirements for VAT Exemptions on
Exports
What happened?
On July 1, 2025, the German Ministry of Finance has amended the
VAT Application Decree (UStAE) to implement the CJEU's
abuse-of-law rulings (Cartrans, Vinš, Unitel) and provide
clearer guidance on when export supplies can still benefit from VAT
exemption in the absence of formal customs confirmation. According
to the new guidance, the exemption is to be granted where the
material conditions for an export can be demonstrated using
objective criteria, even if formal documentary requirements are not
fully met. This includes scenarios where customs stamps are
unavailable – for instance, in airport retail, deliveries to
diplomatic missions, or military exports. The revised decree now
lists acceptable forms of alternative proof, such as certificates
from German public bodies (including the Ministry of Foreign
Affairs and the Bundeswehr), verified customs clearance documents
from