Germany: Ministry of Finance Publishes Finalized Guidelines on B2B E-invoicing

Inês Carvalho
October 16, 2024

On October 15, 2024, the German Ministry of Finance (MoF) published the finalized guidelines on the upcoming B2B e-invoicing mandate, confirming the announced roll out date of January 2025.

The final guidelines have not changed the key requirements established by the Growth Opportunities Act, instead confirming the content of the draft guidelines published earlier this year and clarifying other aspects, such as:

  • E-invoices must comply with EN 16931 syntaxes or a mutually agreed format that meets the requirements, such as XRechnung and the hybrid format ZUGFeRD (from version 2.0.1), excluding MINIMUm and BASIC-WL profiles

  • The trading parties’ ability to determine the e-invoice format under civil law is highlighted and France’s Factur-X and the Peppol-BIS Billing formats are also mentioned as compliant examples.

  • The issuer may rely on the recipient’s VAT ID to ascertain if they are acting as a domestic entrepreneur.

  • While e-mail, use of an electronic interface or a shared access to a central storage location are all accepted transmission methods, the trading parties are free to agree on their preferred method under civil law.

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Author

Inês Carvalho

Inês Carvalho is a Senior Regulatory Counsel at Sovos, specializing in Value Added Tax (VAT) compliance and global e-invoicing trends. Inês holds a Bachelor’s degree in Law and a Master’s in Company Law from Universidade Católica Portuguesa, having worked as a tax consultant at EY Portugal and as registered tax lawyer.
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