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New e-invoicing requirements under discussion

  • Germany has proposed mandatory e-invoicing requirements for B2B supplies by German-established companies from January 1, 2025.
  • E-invoicing is an invoice issued, transmitted, and received in a structured electronic format that allows for electronic processing.
  • The proposal takes into account the new EU e-invoicing rules, allowing member states to introduce e-invoicing requirements from January 1, 2024, provided they are in line with the relevant EU standard. (This is in the meantime being postponed till most likely 2026)
  • Taxable persons established in Germany would be required to issue e-invoices for B2B supplies subject to VAT in Germany.
  • Hard copies or PDF versions of invoices would be allowed in addition to e-invoices.
  • A platform operator would have to validate an e-invoice before issuing it to a B2B customer and provide specific information on the transaction to the German tax authorities.
  • The government will review feedback and intends to publish a legislative proposal to amend the German VAT law this summer.

Source BDO

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