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Germany B2B real-time e-invoicing January 2025

Mandatory B2B domestic real-time e-invoicing reporting Jan 2025; likely phasing for medium & small enterprises

The Federal Ministry of Finance (Bundesministerium der Finanzen or BMF) has issued a discussion document this week around its proposed mandatory e-invoicing live reporting regime.  The consultation will end 8th May 2023.

Key features under consideration include:

  • Structured e-invoicing mandatory for live reporting to the tax authorities at the same time as issuing e-invoice to customers;
  • New definition of structured e-invoices, based on ViDA, and out-of-scope invoices (use of PDF’s and paper invoices);
  • Likely that taxpayers will be able to report via e-invoicing agents or similar outsourced services to the government and their customers at the same time – no pre clearance with the government required;
  • Domestic B2B supplies only;
  • No clarity yet if this includes non-residents issuing or receiving invoices for domestic transactions;
  • Potential staggered introduction for small and medium sized taxpayers’ sales invoices – although they would still be obliged to receive purchase e-invoices from their German suppliers from 2025;
  • Potential threshold for low-value invoices, which would then be phased out;
  • Based on EU e-invoicing standard EN 16931, and the seller’s reporting would be obliged to verify complete reporting of all data fields; and
  • Complies with EC’s proposed VAT in the Digital Age reforms – see 2028 Digital Reporting Requirements for Intra-Community supplies.

This proposal follows a 2022 commitment from the new coalition government to introduce a digital reporting regime to help tackle the VAT Gap.

Nov 2022: Germany applies for temporary departure from Articles 218 and 232 of VAT Directive to impose mandatory electronic invoicing on certain B2B transactions.

Germany is to follow Italy, France, Poland and others by introducing mandatory electronic invoices. It has commenced plans by seeking permission from the European Commission to do so – under the EU Directive rules, businesses must first seek their suppliers’ permission to adopt e-invoicing.

Update: since this announcement, the EC has proposed removing e-invoice derogation approval from January 2024. Once the feedback has been considered, a Bill will be submitted to Parliament.

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November 2021: Coalition new leaders confirm electronic invoice reporting system as soon as possible to fight VAT fraud; backing for EU definitive VAT system; import VAT reforms

The new German government coalition of the SPD, Free Democratic Party (FDP) and Green Party have now confirmed on 24 November 2021 plans to implement a country-wide live e-invoicing regime. It is envisaged that this will validate in real-time the creation of sales invoices by taxpayers, and then act as the forwarding channel for invoices to customers. This follows the Italian SdI model, with Continuous Transaction Controls (CTC)which in turn follows similar models adopted across South America and Asia Pacific.

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The new government has also restated its support for the proposed EU definitive VAT system, which aim to shift the EU VAT regime to a destination principle. Check VAT Calc’s global live VAT invoice transaction and e-invoice reporting tracker to see where else real-time submissions of invoices is being implemented. Our VAT Calculator can produce accurate invoice calculations and reporting globally.

The coalition has also committed to reform the import VAT rules to provide similar reverse charge relief as is common across the rest of the European Union. Read more about German VAT in our national guide.

Germany e-invoice proposal – FDP calls for e-invoicing

The German Bundestag parliament had called for the adoption of B2B mandatory e-invocing to help combat VAT fraud. This follows the successes in ItalyHungary and plans for Poland and France in 2023. There is already a public platform for small and medium sized businesses to use, Zentrales Rechnungseingangsportal OZG-RE platform

Adoption of a standard German regime will be challenge given the independence of the 16 federal states.

The German Free Democratic Party leader, Christian Lindner (now the Finance Minister in the new government), had already raised the issue with a required:  “calls for an electronic reporting system comparable to the Italian Sistema di Interscambio to be introduced nationwide as quickly as possible, which can be used for the creation, checking and forwarding of invoices.”

Germany B2G e-invoices

As per the requirements of the EU VAT Directive on e-invoicing, in April 2020, Germany mandated the acceptance of electronic invoices for Federal governmental transactions with the commercial sector, B2G.The format varies by state (Bundesland) as they adopt the legislation in their local laws. The states have the option of their own format (which should be PEPPOL compliant) or the recommended by Core Invoice User Specification (CIUS).

Europe e-invoicing and live reporting

Country Date Comments (click for details)
EU e-invoice proposals 2028 Digital reporting and e-invoicing harmonisation
Albania Jan 2021 Authorised e-invoice software and pre-clearance
Belgium Jul 2024 Phased introduction of B2B e-invoices
Bulgaria 2023 Public consultation on pre-clearance model e-invoice
Croatia 2025 B2B mandatory e-invoicing
Denmark 2024 Digital record keeping obligations
Finland Apr 2020 Customer option to require B2B e-invoices
France Jul 2024 E-invoicing and e-reporting for B2B and B2C
Germany Jan 2025 B2B mandatory e-invoicing proposals
Greece Oct 2021 myData summary invoice and ledger reporting
Hungary Jul 2018 RTIR live invoice reporting. No govt pre-clearance required
Italy Jan 2019 Pre-clearance SdI e-invoicing
Ireland TBC Public consultation underway
Latvia Jan 2025 B2B e-invoices based on PEPPOL
Lithuania ? E-invoicing platform being scoped
Netherlands - Unlikely to adopt domestic reforms
Poland Jul 2024 B2B mandated e-invoicing
Portugal Jan 2024 Certified invoicing software for non-residents
Jan 2024 ATCUD digital invoice signature for non-residents
Romania Jul 2022 RO e-invoicing implementation
Russia TBC Extension of Traceability Model to B2B on hold
Serbia Jan 2023 B2B e-invoicing
Slovakia 2025 B2B and B2C e-invoice rollout
Slovenia 2023 ? e-SLOG B2B proposal stalled
Spain 1 Jul 2017 SII live invoice and book reporting
Spain 2 2024 Pre-clearance B2B e-invoices; supplement to SII
Sweden TBC PEPPOL based mandatory e-invoicing
Turkey Jan 2014 e-invoice e-Fatura and e-Arşiv
UK Apr 2022 MTD for VAT extended to 1.1million taxpayers


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