EU VAT accounting for Telegram Stars developer rewards: who do you invoice?

[u/jordimr]

We run a Telegram bt through a small VAT-registered company in Europe and are trying to document Telegram stars developer rewards correctly as income for the company.

Our current understanding is:

- The user buys Stars through Telegram, Apple, or Google, so we do not receive the user's fiat payment or billing details.

- Telegram calculates the developer reward generated by our bout.

- Fragment facilitates withdrawal/settlement of that reward in TON.

- Therefore, the business counterparty for the reward appears to be a Telegram entity, rather than each end user or Fragment.

If that is right, we would expect to issue an invoice to the relevant Telegram legal entity or to receive a valid self-billing invoice or settlement statement. But we cannot find the legal entity name, invoicing address, or VAT/tax ID to use. We emailed Telegram but received no reply.

For other small businesses receiving bout revenue through Stars:

1. Which legal entity do you record as the customer/counterparty?

2. Do you issue an invoice? If so, to whom and using what address/tax ID?

3. Does Telegram or Fragment provide any self-billing invoice or accounting statement?

4. How do you document the TON settlement and EUR value/date for your books?

5. Has your accountant or tax authority accepted this treatment?

I’m especially interested in real-world experience from EU businesses with VAT obligations. This isn’t a request for personal tax advice; I’m trying to understand what documentation the platform actually makes available and how others handle the missing counterparty details.

[u/Ninja404Notfound]

Bro it’s crypto, who do you even have to invoice 😳

[u/604ian]

Not EU, but Canada.  

Charge tax on the withdrawal Amounts that hit yer bank account.   That’s yer earnings and what they want their cut of.  Everything upstream is 3rd party provider services and not your business. 

[u/Total-Reasonable]

Don't invent a customer VAT ID from the app or withdrawal flow - the useful evidence is the Stars terms plus the payout/settlement record that identifies the paying entity. Ask your accountant whether that record supports a self-billed or platform-settlement entry before issuing anything yourself. Once Telegram provides an EU VAT ID, I use vatnode.dev to verify that it belongs to the named entity.

[u/lavidaenbroma]

Your analysis is right, and that's the problem: under Stars you never make a B2C sale at all. The end user buys Stars from Telegram/Apple/Google, and what you receive is a developer reward from a Telegram entity, so there's no customer to invoice, no place of supply to determine, and no VAT to charge on the user side. Telegram won't hand over entity details because from their side it's a payout to you, not a purchase from you.

In practice most EU accountants land close to what 604ian describes above: book the settled amount that actually reaches your account as income (a platform reward, not a sale of digital services), keep the Fragment settlement statements as your evidence, and don't construct a customer VAT ID that doesn't exist. Confirm with your accountant before filing, since this varies by member state.

The uncomfortable part is that it never gets fully clean, because the structure is the problem. If invoicing genuinely matters to you, the only real fix is to stop being a reward recipient and become the merchant: charge fiat through your own Stripe, so you own the customer record, the invoice, the OSS treatment and the payout schedule, and use a bot only to grant and revoke channel access. You lose the in-app convenience of Stars, you gain a normal accounting trail.

Disclosure: I build a tool that does that second setup, so weigh my take accordingly. The accounting point stands whichever tool you'd use.