Germany: B2B E-Invoicing Draft Guideline Released

Dilara İnal
June 24, 2024

The German Ministry of Finance (MoF) released a draft guideline on June 13, 2024, detailing the upcoming B2B e-invoicing mandate.

The highlights from the guidelines are that:

  • The MoF plans to introduce an e-reporting system for invoice details at a later stage, with no set date.
  • E-invoicing exemptions include tax-free services, invoices under 250 euros, and travel tickets.
  • E-invoices must comply with EN 16931 syntaxes or a mutually agreed format that meets the requirements. They can be structured or hybrid with a human-readable part. If discrepancies occur, the electronic data takes precedence. Accepted formats include XRechnung, ZUGFeRD (from version 2.0.1), and international standards like Italy’s FatturaPA and France’s Factur-X.
  • E-invoices can be sent via email, electronic interfaces, or portals, but for example not on USB sticks.
  • Recipients who cannot accept e-invoices cannot demand alternatives, and issuers fulfill their VAT obligations if they make documented efforts to send e-invoices.
  • Corrections must be in electronic form.
  • Issuers can rely on recipient-provided domestic entrepreneur status unless there is contrary information.
  • Recipients must ensure e-invoicing compliance. Non-compliant invoices, such as PDFs or paper, are not valid for tax deductions.
  • The structured part of an e-invoice must be stored in its original, immutable form.

The final version of the guideline is expected by Q4 2024. For more details on the German B2B e-invoicing mandate, you can visit our website.

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Author

Dilara İnal

Dilara works as a Regulatory Consultant at Sovos. Before joining Sovos, Dilara worked as a lawyer in tax law and is currently pursuing her master’s degree in financial law at Istanbul University.
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