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Starting on January 1st, 2025, business owners operating within Germany's borders will be mandated to utilize e-invoicing for all local transactions subject to tax that occur between companies based in the country. This mandate particularly impacts those entrepreneurs who operate a permanent establishment in Germany, as it may be implicated in the supply chain. However, simply having a VAT registration for a company established outside of Germany does not trigger the requirement to issue or receive electronic invoices.
A transitional period will be in place for the generation of electronic invoices, although this leniency does not extend to their reception. For a limited time, until the end of December 2026, business owners may opt for alternative invoicing methods, such as traditional paper or the widely adopted PDF invoices. This grace period extends an additional year, until the end of December 2027, for business owners whose annual turnover did not surpass €800,000 in the preceding year and also applies to the creation of EDI invoices.
The Ministry of Finance is set to publish a directive that will clarify unresolved matters and respond to queries concerning various aspects of the electronic invoicing mandate, including its implications, the eligibility for VAT deduction when the e-invoice issuance requirement is overlooked, the specifics of technical implementation, the handling of recurring invoices, and the consequences of non-compliance. The business community is keenly anticipating the release of this directive and the updated invoicing standard, which will align with the European Union's norm EN 16931.
It is advisable for entrepreneurs who will be impacted by these upcoming regulations to start acquainting themselves with the electronic invoicing system and initiate preparations for the impending changes that will take effect on January 1, 2025. It is particularly important to assess and possibly update ERP systems and internal procedures to ensure they are compliant with the new requirements.
You can find the Act to Strengthen Growth Opportunities, Investment, and Innovation, as well as Tax Simplification and Tax Fairness (Growth Opportunities Act), on our Fiscal Portal:Growth Opportunities Act
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