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Germany issues regulatory changes for mandatory e-invoicing

Monday 11th September, 2023

During the summer the German Federal Ministry of Finance shared a draft “Growth Opportunities Act” with significant German business associations. It introduces amendments to VAT law to implement mandatory e-invoicing, along with other tax-related proposals.

Currently, issuing an electronic invoice requires the buyer’s consent. Proposed amendments will change this, with invoices for transactions between German resident taxpayers – known as domestic B2B transactions – required to be electronic. According to a news item by SOVOS.

The act also introduces a new definition for e-invoices. An electronic invoice is defined as an invoice issued, transmitted and received in a structured electronic format that enables electronic processing. An e-invoice must also comply with the eInvoicing standard of the European Committee for Standardization (CEN), EN 16931.

The date remains the same for the Ministry previously shared plan to roll out mandatory e-invoicing as of January 2025.

• Paper invoices will be accepted until the end of 2025. Also, electronic invoices that do not comply with the CEN standard can be issued if the buyer’s consent is obtained. However, electronic invoices based on the CEN standard can be issued without the buyer’s consent.

• E-invoices do not have to meet the CEN standard until the end of 2027, if transaction parties agree and exchange invoices via electronic data interchange (EDI).

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