Marginal VAT, GoBD and liquidity: finances of the German tourism industry
A tour operator buys hotels, flights, and transfers from third parties. Then it sells them as one package tour and pays VAT only on the difference between the selling price and the purchase price. This is how § 25 UStG works, and because of it, the finances of a travel company differ from those of an ordinary business.
The tourism sector in Germany is held mainly by small and medium-sized companies. Add seasonality, currency transactions, and strict document retention requirements, and you get a separate discipline within accounting.
This is an overview of the key accounting areas. You will see where errors most often occur, which VAT regime to apply, and what to check before the season starts.
Special VAT regime: § 25 UStG
💡 In short:
- Check whether you fall under the margin VAT regime: you sell a tour in your own name and purchase partner services.
- Separate direct tour costs from general company costs.
- Set up document retention under GoBD in advance, not at the end of the year.
- Requirements for storing electronic documents: 10/2026, per the GoBD text on the German Federal Ministry of Finance (BMF) website.
§ 25 UStG describes margin taxation for travel services. The rule applies throughout the EU and is designed for operators that act in their own name and purchase partner services (Reisevorleistungen).
Tax is charged not on the entire tour price, but only on the difference between the selling price and the purchase price from partners. In return, input tax on these purchases cannot be deducted. For accounting, this means one thing: direct tour costs must be separated from general company costs, and you will have to maintain this separation constantly.
How such accounting works in practice is examined in detail by the reference portal buchhaltungs-leitfaden.de. Pure agencies that sell other companies' tours in someone else's name do not fall under § 25 UStG. They pay tax only on their commission.
The rule has two consequences. First: if a partner service is provided outside the EU, that part may be exempt from tax with documentary evidence. Second: in accounting, you must separately show the amounts the customer paid, the purchase amounts from partners, and the margin itself, as well as their allocation between taxable and non-taxable parts.
GoBD and electronic documents
A travel company receives a daily flow of electronic documents: booking confirmations from foreign partners, invoices from international hotel platforms, payment advices from payment services. All of them must be kept in the archive in unchanged form and be machine-readable.
The GoBD principles as amended on 14.07.2025 require storing these documents in electronic form and not changing them after posting (BMF, GoBD 2025, as of 10/2026). Books and accounting records are kept for 10 years (§ 147 AO).
For cash points, such as souvenir shops or food service in a hotel, a cash register with a certified technical security system TSE has been mandatory since 2020 (KassenSichV). Choose an ERP system that archives the document from booking to payment itself, so you do not collect papers manually and do not risk problems during an audit.
Separately, procedural documentation is required. It describes how the company receives, posts, and stores documents. Without it, the tax office may assess turnover based on its own data. For an audit, the archive must provide direct read access or export in a common format.
International payments and currency risks
Tourism is a global business, and this is visible in accounting. Revenue from a Swiss client arrives in CHF, the hotel purchase is in USD, and reporting must be done in euros. Conversion is done on the correct date, usually on the booking or payment date.
Exchange rate differences arise on their own, and they must be accounted for, otherwise you will get a discrepancy in reporting. It is more complex with cross-border services within the EU. If a German company conducts excursions directly in Austria, it may have an obligation to register for VAT in Austria.
Within the EU, the reverse charge mechanism under § 13b UStG applies to many services: the tax is shifted to the recipient of the service, and this must also be reflected in reports. Where the place of supply arises for private customers is shown in the table (under the rules of § 3a UStG).
Type of service | Where VAT arises |
|---|---|
Hotel accommodation (rental) | At the hotel location, for example in Italy |
Air transport | At the place of transport, by route segments |
Intermediation (travel agency) | At the agency location, i.e. in Germany |
Package tour (operator) | At the operator location, i.e. in Germany |
Controlling and liquidity management
Because of seasonality and high prepayments for allotments (flights, hotels), liquidity management becomes a matter of company survival. An ordinary BWA (betriebswirtschaftliche Auswertung) is not enough here.
You need your own key indicators:
- RevPAR (revenue per available room) for hotels.
- Load factor for transport and allotments.
- Contribution margin per tour or customer for portfolio management.
- Cancellation rate as an early signal of problems.
A separate topic is expense reports for employee business trips, for example guides. Per diems and accommodation expenses are kept within German norms, and rates are taken from official tables, which differ for Germany and for foreign trips.
Customer money for a service not yet provided is not revenue; it is shown as liabilities (erhaltene Anzahlungen) until the service is provided. Insurer contributions are classified as operating expenses. Operators with turnover from €10 million per year are required by law to insure customer money through the Deutscher Reisesicherungsfonds (drsf.reise, as of 10/2026).
Digital interfaces and automation
Automation is changing document processing. AI-based systems recognize invoices from foreign partners, allocate them to accounts, and post them in accounting. This reduces the number of errors and gives management data almost in real time.
Interface requirements are also growing: exchange with the tax advisor must work without disruptions, preferably through a standard interface such as DATEV. A standard interface reduces manual reconciliation and speeds up the month-end close. For a travel company, choosing the right industry software and an advisor who understands the complexity of § 25 UStG becomes a strategic factor.
⁉️🤔 Frequently asked questions
Does a small hotel need double-entry bookkeeping?
It all depends on the legal form and thresholds. A GmbH or UG always keeps double-entry books. A sole proprietor can use the simplified EÜR form as long as turnover does not exceed €800,000 and profit does not exceed €80,000 (§ 241a HGB). The threshold is calculated over two consecutive years.
How does the margin regime differ from ordinary VAT?
Under ordinary VAT, tax is charged on the entire selling price, and input tax on purchases can be deducted. Under the margin regime, tax is charged only on the difference between the tour price and the purchase of partner services, but input tax on those services is not deductible. This is the key difference for an operator.
How should tour cancellation fees be posted?
This is a delicate point. A genuine cancellation fee as a lump-sum compensation for damages is usually not subject to VAT. If the company calls it a processing fee or invoices it for an already provided part of the service, VAT arises. Check the wording in the contract with the customer.
Does a souvenir shop need a cash register with a TSE system?
Yes. As soon as you use an electronic cash register, the Kassensicherungsverordnung applies to it. The cash register must have a certified technical TSE system that protects every transaction from changes. This also applies to small cash points, such as a souvenir kiosk.
How should customer prepayments be shown?
Customer money for a service not yet provided is not revenue. It is shown as liabilities (erhaltene Anzahlungen) until the service is provided. Insurer contributions are classified as operating expenses, and these are two different positions in accounting. They must not be mixed, otherwise both the balance sheet and the tax base will suffer.
In short: what to check before the season
Accounting in tourism rests on four pillars: the correct VAT regime, clean document retention under GoBD, currency conversion, and liquidity control. If you have a seasonal business with high prepayments, start with liquidity and the archive. If you organize tours in your own name, check the separation of direct and general costs and the margin tax procedure.
Before the season, check four points:
- Whether you fall under the margin VAT regime.
- Whether the archive works under GoBD and whether TSE is present on cash registers with cash.
- Whether interfaces to the tax advisor are set up.
- Whether customer money is insured.
Make this list and go through it with your tax advisor before the first booking.
A small editorial team writing guides for independent travel. We travel ourselves, but we haven’t been everywhere, so we check prices, opening hours and how to get there against official sources.