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Germany Draft Growth Opportunity Act which contain details about new e-Invoicing System

The German Federal Ministry of Finance (BMF) has published a draft (“Growth Opportunity Act”) regarding a tax reform bill which includes mandatory e-Invoicing implementation for business-to-business transactions (B2B) in Germany. Expected timeline of adaptation of the act is by the end of 2023.

Essential bullet point as to mandatory e-Invoicing in Germany as below: 

  • Definition: From 2025, an e-invoice would be defined as an invoice issued, transmitted and received in a structured electronic format that enables electronic processing. All other invoices (e.g. paper or PDF invoices) would be considered to be “other invoices”.
  • Format: Issued invoices should meet requirements of Directive 2014/55/EU (CEN-standard 16931). However, other formats, in particular paper or PDF invoices, would still be permitted until 31 December 2025.
  • Obligation: The B2B e-invoicing obligation would not affect supplies to taxable persons established abroad or to private customers. In other words, taxable persons established in Germany would be required to issue e-Invoices for B2B transactions.


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