General
The new letter deals with the e-invoicing obligation for transactions between entrepreneurs resident in Germany, which has been considered a passive obligation (receipt of invoices) since 2025, but is not to be introduced as an active obligation until 2027 or 2028.
The new letter is essentially intended to transfer the letter of 2024 to the VAT Circular, but without repealing this letter, which instead amends and supplements it in some points.
Changes to the 2024 Letter
The letter comments in detail on errors in the e-invoice. First, it distinguishes between format errors and format-specific business rule errors:
- Format errors occur if the invoice file does not comply with the permitted syntaxes or their technical specifications
- Business rules are technical regulations for checking the logical dependencies of the information contained in an e-invoice
According to the BMF, both categories of errors can be checked with a suitable validation application.
Key Takeaways
- Format errors can lead to the invoice not meeting e-invoice requirements
- Errors in business rules lead to an e-invoice being present but not in order
- Validation applications can help identify both types of errors
- The introduction of e-invoicing is of utmost importance for German economic operators
Note
The complex regulations and questions of doubt cannot be presented here in any way exhaustive – it is recommended to seek tax advice on this issue.