Germany Updates and Expands VAT Exemptions
for NATO Headquarters

The German Federal Ministry of Finance (Bundesministerium der Finanzen – BMF) issued a circular on November 14, 2025, updating the regulations concerning Value Added Tax (VAT) exemptions based on the Supplementary Agreement to the Protocol on NATO Headquarters. This circular specifies the application of VAT exemptions under $\S 4$ No. 7 Sentence 1, Letter d UStG (VAT Act) and significantly expands the list of NATO entities covered by the exemption9999.

The regulations stipulate that supplies and services carried out von a NATO Headquarters, as well as supplies and services zu a Headquarters, are exempt from VAT under certain conditions10. These conditions largely correspond to the VAT exemptions outlined in Article 67 of the Supplementary Agreement to the NATO Status of Forces Agreement (NATO-Truppenstatut)11.

Key Updates and Scope:

• The circular replaces and supersedes the previous BMF letter dated October 9, 202312.
• The list of NATO Headquarters has been extensively broadened to include numerous new military and support units located within Germany und within the territory of other EU member states13131313.
• Entities newly covered in Germany include Headquarters Joint Support and Enabling Command (HQ JSEC, Ulm) and the newly established HQ NATO Security Assistance and Training for Ukraine (NSATU, Wiesbaden)14.
  
• Other locations across the EU now covered include: HQ JFC Brunssum (Netherlands), HQ JFC Naples (Italy), JFTC (Poland), various COEs (Centres of Excellence), and NATO Force Integration Units (NFIU) 151515151515151515.

These regulations clarify the application of VAT exemption for both NATO Headquarters and other international organizations and their members located in other member states16.

https://www.bundesfinanzministerium.de/Content/DE/Downloads/BMF_Schreiben/Steuerarten/Umsatzsteuer/…