How to Create Compliant VAT-Exempt Invoices for EU B2B Orders on Shopify

A Shopify order confirmation is not a valid invoice. See what an Article 138 exempt EU B2B invoice needs and how to generate one correctly.

You sell to VAT-registered businesses in other EU countries, you correctly leave VAT off the sale, and then the customer’s accountant asks for a proper invoice. The order confirmation Shopify emails out is not it. A confirmation is a receipt of what was bought, not a legally valid invoice, and it does not carry the legal basis that an exempt cross-border B2B sale requires. If you cannot produce a compliant document, you risk delays getting paid and questions you would rather not field during a VAT review. Our EU Tax Exemption app for Shopify creates a compliant invoice for these orders automatically.

Why Shopify alone is not enough

Shopify is excellent at taking the order. It does not, on its own, issue an invoice that meets EU requirements for a tax-exempt intra-Community supply. Two things tend to go wrong. First, the exemption is described incorrectly. A cross-border sale of goods to a VAT-registered business in another EU country is an intra-Community supply, exempt under Article 138 of Directive 2006/112/EC. It is an exemption, not a 0% rate, and it is not “reverse charge”. Reverse charge wording belongs to services and certain domestic cases, not to cross-border goods. Second, the document is missing details a real invoice needs, such as the buyer’s VAT number and a proper sequential number.

If your exempt orders are still getting taxed at checkout in the first place, that is a separate problem worth fixing before invoicing. See our guide on why tax-exempt customers still get charged VAT.

What a compliant intra-Community invoice needs

For an Article 138 exempt sale, the invoice should clearly show:

  • Both VAT numbers. Your VAT number as the seller, and the buyer’s VAT number, captured as they were at the time of sale.
  • The VAT line marked as exempt, shown as “Exempt”, not “0%”. Wording matters because an exemption and a zero rate are not the same thing.
  • The legal mention printed on the document, pointing to the Article 138 exemption for the intra-Community supply.
  • A sequential, gap-free invoice number. EU rules expect invoice numbers to run in an unbroken series with no gaps.
  • Full seller and buyer details and the date of supply.

How the app generates it correctly

Our EU VAT exemption app now produces this document for you. When a qualifying cross-border B2B order is placed, it generates a legally valid PDF invoice that uses the correct legal basis for goods, the Article 138 intra-Community exemption, and prints the matching legal mention. The VAT line reads “Exempt”, and the buyer’s VAT number and your seller details are captured as a fixed snapshot, so the invoice reflects the facts at the moment of sale.

Numbering is handled for you in a sequential, gap-free series, which is one of the trickier requirements to get right by hand. The app can email the invoice to your customer automatically when the order is paid, or you can send it on demand. The email goes out under your own business name with replies routed back to you, so it stays on brand. Every PDF is stored so you can download it again later, which makes it far easier to prove your tax exemptions to EU authorities if asked. Invoices are available in English, Dutch, German and French. When it is time to file, you can also export your exempt orders with VAT IDs for your accountant.

This article is general information and not tax advice, so confirm the specifics for your situation with your accountant.

Get compliant invoices from your next order

Stop patching order confirmations and stop worrying whether your exempt invoices will hold up. Install the EU VAT exemption app and start issuing correct, Article 138 compliant invoices for your EU B2B orders straight away.

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