Vouchers and VAT 2025/2026: Key Considerations for Restaurant Operators

Vouchers are the perfect gift idea: flexible, personal, and always suitable. However, for hospitality and hotel businesses that use voucher systems, they may become a tax trap. Recent legislative changes in VAT law require the utmost care in the accounting treatment of vouchers, particularly those issued in 2025. The first practical cases in the new year already demonstrate where the pitfalls lie in the details.

Single-purpose or multi-purpose voucher? A clear and straightforward explanation of the VAT classification.

From a VAT perspective, not all vouchers are the same. What is decisive is whether, at the time of issuance, it is already clearly determined which VAT rate will apply to the subsequent supply.

Single-Purpose Voucher

A single-purpose voucher exists if, at the time of issuance or transfer, the place of supply and the VAT due are already determinable. In this case, VAT becomes chargeable already upon issuance. The subsequent redemption is no longer relevant for VAT purposes as an independent transaction.

Classic examples of single-purpose vouchers:

• Beer voucher for “1 litre of beer”
• “Breakfast voucher for two”
• €50 restaurant voucher (exclusively for on-site consumption)
• “One overnight stay in a double room.”

Important: If a single-purpose voucher expires without being redeemed, such expiry ultimately results in VAT being charged on the received payment.

Multi-Purpose Voucher

A multi-purpose voucher exists if, at the time of issuance or transfer, the supplying business, the subject matter of the supply, or the place of supply has not yet been definitively determined and, as a result, the VAT due cannot be determined.

Consequently, the issuance of a multi-purpose voucher is, in the first step, irrelevant for the amount of taxation. Only upon redemption of the voucher is the respective transaction subject to VAT.

Classic practical examples of multi-purpose vouchers:

• Hotel value voucher for accommodation and catering
• “Festival token booklet”
• €50 restaurant voucher (including takeaway)

In summary, the following applies: The greater the freedom of choice (range of goods/services, timing, food and beverages), the more likely it is that a multi-purpose voucher exists.

In practice, from a business perspective, the multi-purpose voucher is often the preferred instrument due to the deferred VAT taxation (only upon redemption of the voucher). If the voucher expires or is not redeemed, no transaction subject to VAT occurs.

VAT 2026: When Vouchers Become a Risk for Your Cash Register System

Since 01 January 2026, many hospitality businesses will be required to differentiate VAT rates for on-site consumption: whereas previously it was often simply “19% VAT”, food will now be subject to 7% VAT and beverages to 19% VAT.

This directly affects voucher treatment:

• Multi-purpose vouchers will become more common, because at the time of issuance it is often no longer clear which VAT rate will apply later (e.g. when issuing a classic breakfast voucher for on-site consumption).
• For single-purpose vouchers issued in 2025 but redeemed in 2026, there is a risk of double taxation or incorrect VAT treatment if the cash register system mistakenly treats redemption as a new taxable transaction.

Example 1: Restaurant Value Voucher as a “Classic” Multi-Purpose Voucher

Case: A €100 voucher is sold on 20 December 2025, redeemable for food and beverages regardless of the place of consumption. It is redeemed on 10 January 2026: food €70, beverages €30.

Solution:This is typically a multi-purpose voucher, because it can be redeemed for supplies subject either to the reduced VAT rate or the standard VAT rate—meaning the VAT due cannot be determined conclusively at the time of issuance.
VAT is therefore only triggered upon redemption – then applying the VAT rates valid from 2026 (food 7%, beverages 19%).

Example 2: Breakfast Voucher as a Single-Purpose Voucher

Case: A café sold breakfast vouchers until 31 December 2025 and treated them as single-purpose vouchers (at that time: clearly 19% VAT at issuance). Redemption takes place in February 2026—where the food portion would now be 7% and beverages 19%.

Solution: A voucher that has already been taxed as a single-purpose voucher does not “automatically” become a multi-purpose voucher due to the change in VAT rates. For single-purpose vouchers, the issuance constitutes the taxable and VAT-liable supply; the later redemption is irrelevant for VAT purposes.

Important:
The key consequence is mainly technical: if your cash register system nevertheless issues VAT upon redemption, this can quickly result in an error pattern (double taxation or incorrect VAT treatment).

Any additional payments exceeding the voucher value will be treated in accordance with the new rules effective from 01 January 2026 (allocation of 7% VAT to food and 19% VAT to beverages).

Practical Tips for VAT Treatment of Vouchers: How to Avoid Errors

• Categorise your voucher portfolio: The distinction between single-purpose and multi-purpose vouchers determines the time VAT becomes chargeable. Maintain two clearly defined processes (voucher issuance and voucher redemption) in your cash register system to prevent errors.
• Multi-purpose voucher vs. single-purpose voucher: Review your voucher types. These may change significantly as a result of the legal amendments effective from 01 January 2026. Multi-purpose vouchers offer tax and business advantages.
• Conduct a test run: Run through all possible voucher scenarios in your cash register system and document the results. Check the relevant VAT consequences in each case.

Correct Voucher Processing Through a Simulated Cash Register Audit

In view of the VAT reduction on food effective from 01 January 2026 and the potential loss of tax revenue, it is expected that the tax authorities will pay closer attention to the correct recording of vouchers during cash register inspections and tax audits.

Would you like to ensure that your voucher processes are correctly reflected in light of the legal changes and that your cash register system processes them properly and in compliance with the law?

Then have your cash register system reviewed as soon as possible as part of a simulated cash register audit. We will provide you with specific, legally binding recommendations for implementation in day-to-day operations.

If you have any questions or are interested in a simulated cash register audit, please feel free to contact us.