VAT on Amazon Ads for agencies: rebill the ad spend, or let the client pay Amazon?

Short answer: who Amazon bills decides who carries the VAT. If your client's Advertiser Account is billed, Amazon invoices your client, VAT included, and you invoice only your fee. If your Manager Account is billed, Amazon treats you as the buyer: rebilling the ads is then a sale of advertising, and in the EU and the UK you charge VAT on the whole amount, ad spend included, not only on your fee. Either way, a client who cannot deduct VAT pays it: rebilling moves the VAT, it never removes it.

For agencies, freelancers and in-house teams running Amazon Ads for clients, from Amazon's agreement and help pages, the EU VAT Directive, and HMRC's, Germany's and Spain's texts, checked in October 2026. This is information, not tax advice: confirm your setup with your accountant.

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The two setups at a glance

How do you choose who Amazon bills?

When you create an Advertiser Account from your manager account, Amazon asks whom to bill:

• Manager Account: "if you're a reseller, agency, or partner acting in your own capacity". Your own billing profile pays the ad spend.
• Advertiser Account: "if you're an advertiser or agency acting on behalf of the advertiser". You enter your client's billing details, and the client pays by invoice (the only payment method in this setup).

The billing profile that pays decides the tax. Amazon uses its address and VAT number "for tax calculation and generating commercial invoices". So in the second setup, enter your client's VAT number in their billing profile: without it, Amazon adds VAT the client may not get back.

Amazon's agreement says the same thing from the other side: if you ask Amazon to invoice you, you warrant that you act "as principal" in buying the ads.

Your account is billed: VAT on the whole amount

In the EU, a business that takes part in a service in its own name but on behalf of someone else "shall be deemed to have received and supplied those services himself" (article 28 of the VAT Directive). Amazon sells the ads to your agency; your agency sells advertising to its client. Your invoice is ad spend + fee, with VAT on both. The UK (Notice 700, section 22.6), Germany (§ 3 Abs. 11 UStG) and Spain (article 11.Dos.15º of the VAT law) say the same.

For a registered agency this is neutral: you deduct the VAT Amazon charges you, and your client deducts the VAT on your invoice.

Can the ad spend be a disbursement, outside VAT?

Not when Amazon invoices you. A rebilled cost stays outside VAT only when you paid it as your client's agent, for a debt that was your client's:

• EU: "expenditure incurred in the name and on behalf of the customer", kept in a suspense account (article 79(c)).
• UK: eight conditions, all required, including "your client was responsible for paying the third party" (Notice 700, section 25.1.1).
• Germany: a direct legal relationship between your client and the supplier; someone who must pay the supplier himself is not a mere go-between (UStAE 10.4).
• Spain: sums paid "en nombre y por cuenta del cliente" under an express mandate (article 78.Tres.3º).

With Manager Account billing, the debt to Amazon is yours, so none of these fits. HMRC warns that costs agencies treat as disbursements often "should have formed part of the value of their invoice to the client".

Your client's account is billed: you invoice only your fee

Amazon invoices your client directly, with the VAT that follows the client's billing profile. Your own invoice carries only your fee:

• Client in your country: your country's VAT on the fee.
• Business client in another EU country: no VAT on your invoice; the client accounts for it (reverse charge, articles 44 and 196 of the VAT Directive). The UK works the same way for a business client (Notice 741A).
• Client elsewhere: the rules of the client's country.

Example: €10,000 of ads a month, a €1,500 fee, a French client

A French agency, French VAT at 20%. What the client pays each month, after deducting whatever VAT it can:

• Client billed: Amazon €10,000 + €2,000 VAT, your fee €1,500 + €300 VAT.
• Agency billed: your invoice €11,500 + €2,300 VAT.

The setup changes who sends the invoice, not the VAT. A client who cannot deduct pays €2,300 of VAT a month in both cases, €27,600 a year.

An agency in another EU country does not change it either. A French business under the small-business scheme that buys a service from another EU country "doit payer la TVA, peu importe le montant" and "ne peut pas déduire la TVA" (Service-Public). In Germany, "Auch Kleinunternehmer … schulden die Steuer" (UStAE 13b.1).

Your clients pay VAT they could get back: tell them

Many clients of an agency pay VAT on their ads without getting it back: KDP authors, Merch on Demand designers, small sellers below the VAT threshold. In several countries, registering (or leaving the small-business scheme) gets it back. Helping them check is advice they will remember:

1. Send them the free calculator on their own profile: KDP author, Merch on Demand designer, FBA & FBM seller. They pick their country and their monthly ad spend.
2. Send the article for their country, for example UK KDP authors, UK FBA & FBM sellers or Irish KDP authors. The calculator links each country's article.
3. Let their accountant decide: registering commits them, and in some countries (Spain for authors) it gets nothing back.

Frequently asked questions

Does Amazon put my client's VAT number on the invoice?

With Advertiser Account billing, Amazon computes the tax from the billing details you entered for your client. Enter the client's VAT number there, as Amazon asks: "Make sure that you provide your VAT registration number".

Can an agency outside the EU save its clients the VAT?

No. An EU business client accounts for the VAT itself on a service bought from abroad (reverse charge, article 196), and pays it for real when it cannot deduct it.

Does France's Loi Sapin change anything?

Only for a French client advertising on Amazon.fr. The Loi Sapin lets an intermediary buy ad space only on the advertiser's behalf, under a written mandate, paid by the advertiser alone, with the seller's invoice sent to the advertiser (articles 20 and 21). Since 2015 it covers every medium, online ads included. It applies when the ad benefits a French company and is mainly seen in France (article 27). For those clients, have Amazon bill their Advertiser Account and sign a one-page mandate: you comply, and your turnover is your fee alone, which keeps a small agency under its VAT threshold longer. A French client on Amazon.de or Amazon.com, and any client outside France, falls outside it.

Does this apply to my own agency's ads?

A registered agency deducts the VAT on the ads Amazon bills to it, like any business. The calculator's Agency profile shows the case for your country.

Sources

• Create a new Advertiser Account (5 October 2026), Understand billing and payment profiles (12 January 2026) and Update billing details (9 April 2026), Amazon Ads help
• Amazon Advertising Agreement (posted 23 July 2026), section 4.C "Agency Relationships", Amazon Ads
• Council Directive 2006/112/EC, articles 28, 44, 79 and 196, EUR-Lex
• VAT guide (VAT Notice 700), sections 22.6 and 25.1.1, HMRC
• VTAXPER38500: revenue risks associated with disbursements, HMRC
• VAT Notice 741A: place of supply of services, HMRC
• § 3 UStG and § 10 UStG, and the UStAE 10.4 and UStAE 13b.1, Germany
• Ley 37/1992 del Impuesto sobre el Valor Añadido, articles 11 and 78, BOE, Spain
• Franchise en base de TVA, Service-Public Entreprendre, France
• Loi n° 93-122 du 29 janvier 1993 (loi Sapin), articles 20, 21 and 27, Légifrance, France

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