Questions about Freelancing with international clients under Kleinunternehmer-Regelung

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Hi everyone!

I’ve read through a lot of posts (including this one, which answered some questions
:D) & spoken with an accountant but I am still a bit confused by everything. So, if someone that’s knowledgeable can correct my knowledge of VAT, the Kleinunternehmer-Regelung (KUR) & German law, I would so, so appreciate it!

My situation is the following:


I am a freelance video editor based in Berlin, working under the KUR since October 2020. In the three months of 2020 that I worked as a freelancer, I did not exceed 5500 (22k/12x3), so I remain under KUR in 2021.

Now, I deal mostly with international clients (businesses) but also some German clients.

After speaking with an accountant, he told me
a couple of things that confused me:

  • If the clients are in, say, Hong Kong (outside the EU), and they are businesses the sales I make with that clients do not count towards the Umsatzgrenze for KURI don’t even mention RCV
    • E.g. I make 1000 Euro of sales in January, but 500 is from a client in Hong Kong. For the purposes of remaining within KUR, I’m only 500 Euro closer to the limit, not 1000.
  • He did not say I should get a USt-ID, though I feel that since I’m dealing with international clients so much, I should get one? My understanding is that it is required for the Reverse-Charge-Verfahren (RCV)
    • I know that just having it won’t cost me anything but I’d rather save myself the monthly VAT forms where possible

The following is my understanding of invoicing under KUR, assuming all of my clients are business entities:


  • If they are German, I do not charge them VAT & state so in the receipt (§ 19 UStG)
  • If they are within the EU, but not in Germany, they need to give me their VAT number & then I give them their receipt where I apply the RCV
    • Then, every quarter, I have to forward a Zusammenfassende Meldung to the Finanzamt (to snitch on them, basically). I have to do this if I work with businesses in the EU outside of Germany, even if I’m under the KUR
  • If they are outside of the EU (China, US, Australia, UK) I simply send a normal receipt
    • No mention or charge of VAT
    • I don’t even mention RCV


Is this a correct understanding of things? 

Thank you so much, I'm going to go for another chat with the accountant just to be sure, but I want to be better informed this time around and the internet doesn't seem to have these answers :(

(re-edited thread due to some formatting issues)


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