Invoicing a client in the UK from Germany or Austria
Since Brexit, the reverse-charge sentence you use for EU clients no longer fits a client in London. Here is what goes on the invoice instead.

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Your client in London wants the invoice by the end of the month. You reuse the template for your EU clients, the one with the sentence about the customer owing the tax, and get a query back from their finance team. Since Brexit the UK is a third country, and the sentence from § 14a of the German VAT Act only applies to clients in the EU.
Invoicing a client in the UK from Germany
From Germany you invoice a business in the UK for the net amount, with no German VAT. The place of supply is with the client (§ 3a(2) UStG). The invoice carries a note that the supply is not taxable in Germany. Your client accounts for UK VAT themselves. UK clients do not go into the EC Sales List.
Place of supply under § 3a(2) UStG
For most services to businesses, the place of supply is where the client runs its business (§ 3a(2) UStG). The service is therefore not taxable in Germany, and you show no VAT.
Mandatory details for senders in Germany
Your invoice needs the usual mandatory details plus:
- the net amount with no VAT rate and no VAT amount
- a note that the supply is not taxable in Germany and the place of supply is the client's place of business
- the client's company name and UK address, ideally with their UK VAT registration number
German law only requires the wording "Steuerschuldnerschaft des Leistungsempfängers" (§ 14a(1) UStG) when the client owes the tax in another EU member state. For the UK you do not need it. An English line saying "reverse charge" still helps, because that is the word your client's finance team looks for.
Invoice note from Germany
Nicht im Inland steuerbare Leistung. Leistungsort ist der Sitz des Leistungsempfängers (§ 3a Abs. 2 UStG). Not subject to German VAT. Place of supply is the customer's place of business. Reverse charge: the customer accounts for any UK VAT due.
EC Sales List in Germany
The EC Sales List, filed with the Federal Central Tax Office (BZSt), only covers clients elsewhere in the EU (§ 18a(2) UStG). UK clients do not go on it.
Small businesses in Germany (Kleinunternehmer)
Under the small business rule in § 19 UStG (up to €25,000 in the previous year and €100,000 in the current year) you never show VAT anyway. For a UK business client the correct reason is still the place of supply. Put the place of supply note on the invoice. How to word the small business line is covered in Small business invoice wording.
Private customers: the rule for senders in Germany
As a rule, a service to a private customer is taxed where you run your business (§ 3a(1) UStG). Then the invoice shows 19% German VAT.
For a list of services, § 3a(4) UStG flips that when the private customer lives outside the EU. The list includes the work of lawyers, engineers and tax advisers, translation, advertising, data processing and the supply of information. The place of supply is then with the customer, and you invoice without German VAT.
Invoicing a client in the UK from Austria
From Austria you invoice a business in the UK for the net amount, with no Austrian VAT. The place of supply is with the client (§ 3a(6) UStG AT). The invoice carries a note that the supply is not taxable in Austria. Your client accounts for UK VAT themselves. UK clients do not go into the recapitulative statement.
Place of supply under § 3a(6) UStG AT
For services to businesses, the place of supply is with the client under § 3a(6) of the Austrian VAT Act. The service is therefore not taxable in Austria, and you invoice the net amount.
Mandatory details for senders in Austria
Your invoice needs the usual mandatory details under § 11 UStG AT plus:
- the net amount with no VAT rate and no VAT amount
- a note that the supply is not taxable in Austria and the place of supply is the client's place of business
- the client's company name and UK address, ideally with their UK VAT registration number
You do not need the sentence about the customer owing the tax that you use for EU clients. An English line saying "reverse charge" still helps, because that is the word your client's finance team looks for.
Invoice note from Austria
Nicht im Inland steuerbare Leistung. Leistungsort ist der Sitz des Leistungsempfängers (§ 3a Abs. 6 UStG). Not subject to Austrian VAT. Place of supply is the customer's place of business. Reverse charge: the customer accounts for any UK VAT due.
Recapitulative statement in Austria
The recapitulative statement in FinanzOnline only covers clients in other EU member states. UK clients are not reported there.
Small businesses in Austria (Kleinunternehmer)
The exemption under § 6(1)(27) UStG AT has a limit of €55,000 since 1 January 2025. A service to a UK business is not taxable in Austria, so the exemption does not change the note. Put the place of supply note on the invoice.
Private customers: the rule for senders in Austria
Austria also has services where the place of supply is with a private customer who lives in a third country. For senders in Austria this third country rule for private customers sits in § 3a(14) of the Austrian VAT Act.
Your invoice to the UK with Backbone: Backbone is the agentic back office for teams and agents. Tell your AI chat, ChatGPT, Claude or any other AI with MCP support: "Write an invoice to Thames Studio in London for €2,400 for the October web design, in English, without VAT, with the third country note." Backbone drafts it with 0%, the note and every mandatory detail, and you confirm. Ready in minutes, no bookkeeping knowledge needed.
In the editor, you add the third country note for UK clients yourself, in the invoice's note field. Leave the reverse-charge switch off for UK clients.
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Invoicing a UK business
HMRC also puts the place of supply with the client: under the "B2B general rule" the supply is made where the customer belongs, and the UK client accounts for the VAT under the reverse charge (VAT Notice 741A, sections 5.1 and 6.3).
Ask for the client's UK VAT registration number and keep it with the invoice. It shows that you supplied a business. You can check it with HMRC's service Check a UK VAT number. VIES, the EU system, does not cover GB numbers. Save the result with the date alongside the invoice.
Private customers in the UK
This is where it gets fiddly. The basic rule for your own country is in the section for your country above.
Digital services to UK consumers are liable to UK VAT (HMRC, Digital services to private consumers). The well-known £90,000 threshold only applies to businesses established in the UK. If you have no establishment there, HMRC says you must register from your first taxable supply of any value (VATREG37050). The UK standard rate is 20%.
E-invoicing in the UK
There is no e-invoicing requirement today. A PDF by email is fine. From 1 April 2029, UK VAT-registered businesses must be able to issue and receive VAT invoices as e-invoices. The government published the roadmap with Budget 2026 on 28 October 2026. Cross-border invoices are left out, so your invoice from Germany or Austria to a UK client can stay a PDF. If you are VAT-registered in the UK yourself, your UK domestic invoices follow the same rules as those of UK businesses.
Sample wording
The note for the invoice is in the section for your country above.
Dear Sir or Madam, please send us your UK VAT registration number for our invoice. We will invoice without VAT. Thank you. Sehr geehrte Damen und Herren, für unsere Rechnung benötigen wir Ihre UK VAT registration number. Wir stellen die Leistung ohne Umsatzsteuer in Rechnung. Vielen Dank für Ihre kurze Rückmeldung.
If the invoice stays unpaid, read Payment reminders to the UK.
Why this one matters to us
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Automating back-office work with AI agents and AI integrations is the future – that's why I built Backbone!
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Invoices to the UK, done right. In the app, or in a chat with ChatGPT, Claude and many more.
Invoice to the UK
In English, without VAT, with the note.
In the chat Write a draft invoice for Thames Studio in London: October web design, €2,400, in English, without VAT, with the third country note.
Backbone connectorcreate_documentHere's the draft: in English, 0%, with the place-of-supply note.
DraftInvoiceThames Studio Ltd€2,400.00Created 02/11/2026In the app Check the details
Checked before it goes out. You issue it.
In the chat All set for the UK? Then issue it.
Backbone connectorissue_documentEvery mandatory detail is on it:
- Net, without German VAT
- Note: not subject to German VAT, place of supply at the customer's (§ 3a(2) UStG)
- Thames Studio's UK VAT number: GB298765432
- No EU reverse-charge sentence, no EC Sales List
Issued as RE-2026-0157.
OpenInvoiceThames Studio Ltd€2,400.00RE-2026-0157 · Issued 02/11/2026In the app Off to the client
You approve. Only then does it go out.
In the chat Send it to Thames Studio.
Backbone connectorsend_documentWith dunning on, Backbone sends the reminders if it stays unpaid.
In the app
Try 7 days
Say it in your AI chat. Backbone does the rest, you approve.
You pay €0.00 today. 7-day trial, card required, cancel monthly
General information, not legal or tax advice and no review of your case. Details on providers and laws can change. For your case, follow your tax adviser.
Sources: § 3a UStG (DE) · § 14a UStG (DE) · § 18a UStG (DE) · § 19 UStG (DE) · HMRC VAT Notice 741A · HMRC, When to register for VAT · HMRC VATREG37050 (NETPs) · HMRC, Digital services to private consumers · HMRC Transformation Roadmap update 2026 · GOV.UK, Roadmap for e-invoicing implementation (28/10/2026) · USP Austria, cross-border services · USP Austria, recapitulative statement