VAT invoices in Germany are not just bills – they are tax documents with a precisely defined function. German tax law treats them very seriously. They form the basis for determining the VAT payable or deductible. For a document to be valid, it must meet specific formal requirements and be properly stored. For many Polish entrepreneurs operating in Germany, understanding local invoicing rules is an obligation, not an option.
Issuing VAT invoices – when is it required?
A VAT invoice in Germany must be issued for every B2B transaction, i.e. between companies. This also applies to exports and intra-EU supplies, unless they are VAT-exempt. Deadline? Normally you have 6 months from the date of supply or service. However, there are exceptions: for intra-EU supplies or services under the reverse charge mechanism, the deadline is reduced to 15 days from the end of the month following the supply.
B2C transactions usually do not require invoices, except in specific cases such as construction services or intra-EU distance sales.
Invoice content requirements
The invoice must be clear and complete. It should contain all the required data: supplier and buyer details, description of goods/services, VAT rate and amount, invoice number, issue date, delivery date. Simplified invoices (up to €250) require fewer details: supplier’s name/address, date, description, gross amount, VAT rate.
Invoices in foreign currencies
If you invoice in a foreign currency (e.g. PLN), you still need to convert into euros. You can either use the monthly average rate published by the German Ministry of Finance or your bank’s selling rate on the day of supply. The latter must be documented.
Document storage – who, how, where?
VAT documents must be stored for 10 years. German companies must keep them in Germany, in paper or electronic form (GoBD-compliant). Individuals must keep construction-related invoices for 2 years. Foreign companies may store invoices in another EU country, but only after notifying the tax office in writing.
E-invoicing – mandatory from 2025
From 1 January 2025, e-invoicing will be mandatory for B2B transactions between German-registered businesses, using the CEN EN 16931 format. Recipient consent is no longer required. Paper invoices remain valid until 2026 (2027 for small businesses < €800k).
Collective invoices
Allowed in Germany, covering multiple supplies over a period. They must include all required details, and any different VAT rates must be listed separately.
Self-billing & credit notes
Self-billing is permitted with mutual agreement – the invoice must contain the word Gutschrift or equivalent. Credit notes are standard for corrections.
Electronic control
Authenticity, integrity, and readability must be ensured. If no digital signature/EDI, an internal control system is required. Tax authorities may audit VAT documentation, and payment providers must report cross-border transactions.
What should you do now?
If you operate in Germany, review your VAT documentation, storage method, and systems. Ensure readiness for e-invoicing – because from 2025, half-measures will no longer suffice.