Hi everyone,
I build apps for the Shopify App Store and receive monthly payouts from Shopify International Ltd. (Ireland). My tax adviser now tells me the real contractual partners aren’t Shopify at all, but every single merchant who is billed and is paying for the app. The argument (based on § 3a (2) German VAT law, but relevant in any VAT/GST country) is:
- Shopify’s invoice only shows “Payment”, they forward the money but aren’t the buyer.
- Because the merchant is the actual buyer, I must charge VAT/GST according to the merchant’s location:
- 19 % German VAT for German businesses,
- Reverse-charge for EU businesses with a valid VAT ID,
- OSS or local rules for non-EU or B2C cases.
This seems to clash with Shopify’s own help page, which implies Shopify itself is the customer and the payout is a B2B service to Ireland (reverse charge, no German VAT).
Questions
- Has anyone here been audited or obtained an official ruling that confirms either interpretation?
- If you treat each merchant as the customer:
- How do you get reliable VAT ID / location data when the Partner payout report doesn’t include it?
- Do you issue separate invoices outside the Shopify system?
- Any official Shopify doc or government guidance I’ve missed?
Thanks in advance for sharing your experience!