Facts:

A Swiss entrepreneur E4 (= last purchaser) orders a machine from his Swiss supplier E3 (=2nd purchaser). The latter in turn orders the machine from the German wholesaler E2 (=1st purchaser). Since the wholesaler E2 does not have the machine in stock, he orders it from the German manufacturer E1 (= first supplier).
The German wholesaler E2 instructs his forwarder with the pickup of the machine from the German manufacturer E1 and subsequent delivery to the Swiss entrepreneur E4. The German wholesaler E2 (=intermediary operator) acts with his German VAT identification number and he communicates it to the German manufacturer E1 in writing in the order document at the latest until the beginning of the shipment.

Brief description of the chain transaction:

• "Supply 1" from E1 (Germany) to E2 (Germany)
  • Transaction without transport/dispatch assignment (§ 3 (7) UStG)
  • Taxable supply in Germany (E1)
    
    
• "Supply 2" from E2 (Germany) to E3 (Switzerland)
  • Assignment of transport or dispatch according to § 3 (6) UStG in conjunction with § 3 (6a) sentence 4 - 2nd half sentence UStG and § 3 (6a) sentence 6 UStG
  • VAT-exempt supply in Germany (E1)
  • Tax exemption pursuant to § 4 (1)(a) UStG in conjunction with § 6 UStG (export supply)
    
    
• "Supply 3" from E3 (Switzerland) to E4 (Switzerland)
  • Transaction without transport/dispatch assignment (§ 3 (7) UStG)
  • From a German perspective this is a taxable supply in Switzerland (E4).
    
    
• Special feature of this chain transaction
  • Since the German entrepreneur E2 acts with his German VAT identification number towards the German entrepreneur E1, the provision of the § 3 (6a) UStG applies. As a result, the assignment of dispatch or transport shifts to the supply between E2 and E3 and from a German perspective the German entrepreneur E2 does not have to register in the destination country Switzerland.
    
    

Detailed description from the perspective of the individual entrepreneurs:

From the perspective of the 1st supplier E1 (from Germany):

• Outgoing Invoice:

  • Invoicing:
    This supply is taxable in Germany (E1). The invoice must therefore be issued with 19 % German VAT, stating the own (German) VAT identification number.
    
    
  • VAT Return:
    Declaration of the sales transaction in line 12/code 81 as taxable (domestic) supply.
    
    

From the perspective of the 1st purchaser E2 (from Germany):

• Incoming Invoice:

  • VAT return:
    The German VAT contained in the incoming invoice can be deducted as input tax and must be included in the VAT return in line 37/code 66.
    
    

• Outgoing Invoice:

  • Invoicing:
    Invoice without VAT with reference to the tax exemption (tax-exempt export supply) pursuant to § 4 (1)(a) UStG in conjunction with § 6 UStG (or alternatively with reference to Article 146 of the Directive 2006/112/EC).
    
    
  • VAT Return:
    Declaration of the sales transaction in line 21/code 43 as a tax-exempt export supply.
    
    

From the perspective of the 2nd purchaser E3 (from Switzerland):

• Incoming Invoice:

  • VAT return:
    Whether the import VAT is to be included in the VAT return and if an entitlement to deduct VAT obtains is governed by the legal provisions of the third country and is not analyzed in more detail here, since Switzerland is only an example of many possible third countries.
    
    

• Outgoing Invoice:

  • Invoicing:
    From a German perspective this supply is taxable in Switzerland (E4). The invoice must probably be issued with Swiss VAT. Whether or not this sales transaction is subject to VAT is governed by the legal provisions of the third country and is not analyzed in more detail here, since Switzerland is only an example of many possible third countries.
    
    
  • VAT Return:
    A declaration in the VAT return is governed by the legal provisions of the third country.
    
    

From the perspective of the last purchaser E4 (from Switzerland):

• Incoming Invoice:

  • VAT return:
    A declaration in the VAT return is governed by the legal provisions of the third country.
    
    

Notes to the chain transaction:

• According to the standard conditions in the chain transaction calculator, the export declaration is made by the entrepreneur who arranges the transport. In this example, this would lead to the unusual case that E2 issues an export invoice (without VAT) to E3, but has to pay import VAT in the third country in the course of the export declaration. The evaluation of this example is therefore based on the assumption that the export declaration is made for E3.
  
  
• You can find the German version in the reihengeschaeftrechner.de.