Germany’s Federal Ministry of Finance and Federal Ministry of Justice presented a joint action plan against tax and financial crime, which includes measures relevant to vat reporting and archiving of tax relevant documents.
First, a VAT reporting system is to be introduced to effectively prevent VAT fraud. While no technical detail, scope, or timeline has been published, the direction seems to be consistent with the near real-time, invoice-level reporting models other Member States are already adopting on top of their e-invoicing mandates, suggesting Germany’s existing B2B e-invoicing rollout could become the foundation for a similar reporting layer.
Second, the retention period for accounting documents is to be extended from the current 10 years to 15 years, to ensure access to important evidence. The release does not specify whether this extension would apply uniformly to all categories of accounting records currently covered by the GoBD retention rules, or only to a defined subset considered more relevant to fraud investigations; it also leaves open whether the change would apply prospectively to newly created records only, or retroactively extend the retention clock on documents already within their current 10-year window.
Moreover, companies would be required to store tax-relevant data on mirror servers located in Germany, introducing a data localization requirement. Once again, the mechanics remain undefined, as it is not clear whether “mirror” implies a live, continuously synchronized copy or simply a complete duplicate updated periodically, nor which data falls within scope.
All three measures are announced at policy-plan stage only; none is yet reflected in draft legislation.
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