What content requirements must be observed to create an e-invoice?

According to Section 5 of the Federal Government’s Regulation on Electronic Invoicing, in addition to VAT invoicing elements (for more on this, see Section 14 of the Value-Added Tax Act [UStG]), an e-invoice must contain the following information at a minimum:

  • Buyer reference – you will be given the buyer reference when the contract is awarded.
  • Terms of payment (payment due date or text description of the terms).
  • The payment recipient’s bank details.
  • The invoice issuer’s postal or De-Mail address.

Mandatory information according to Section 5 E-RechV of the federal government and elements / BT (business term or information) items, in which these are to be entered in an XRechnung invoice:

  • Buyer reference: BT-10 – BT = Business term or information item
  • Bank details: for bank transfer: BG-17 (BT-84 to 86); for direct debit: BG-19 (BT-89 to 91) – BG = Business group or group of information items
  • Terms of payment: BT-9 or BT-20
  • E-Mail address: BT-43
  • Supplier number*: BT-29
  • Purchcase order number*: BT-13

* Mandatory information, if transmitted at the time of commissioning

A specific data field is provided for each of these additional details. Further information on the XRechnung invoice standard can be found in the FAQ section on XRechnung invoicing.

Which formal requirements must be observed for the creation of e‑invoices?

The latest version of the XRechnung standard must always be used when issuing e-invoices. Another standard (e.g. ZUGFeRD 2.2.0 XRechnung profile without PDF visual format, as a purely structured XML file) can also be used if it complies with the requirements of the European standard for electronic invoicing (EN 16931), the Federal Government’s Regulation on Electronic Invoicing (E-RechV) and the federal government’s terms of use for the invoice submission platform.

Invoice formats that do not comply with the requirements of the European standard cannot be taken into account.

Invoice supporting documents or attachments must be embedded in the invoice data record and may not be sent separately as an attachment to an email.

The maximum permissible size of an invoice depends on the transmission channel selected (e.g. 10 MB for email attachments or 11 MB for attachments in the web entry). The maximum number of embedded documents supporting the invoice is limited to 200. Permitted file types of the embedded documents are: ‘png’, ‘pdf’, ‘jpg’, ‘jpeg’, ‘xlsx’, ‘ods’ and ‘csv’.“. Attachments may not contain active content (e.g. macros). Changes to these restrictions will be announced via the invoice receipt platform.

Invoice documents with attachments that require paper-based submission under other legal provisions (export certificates, customs documents, etc.) remain unaffected by the above regulations.

More detailed information on the XRechnung standard can be found at KoSIT.

Can I send a PDF as an e-invoice?

No. As defined in EU Directive 2014/55/EU, e-invoicing is a structured data set. A PDF file is not an e-invoice under these requirements.

How can I indicate taxes on used car parts in an e-invoice?

Currently, you can indicate taxes on used car parts as follows:

  • an invoice line indicating the used car part and taxation under tax category code S for the used car part
  • an invoice line indicating the tax base (10% of the value of the used car part) and taxation under tax category code S for the (value-added) tax on used car parts
  • an invoice line with a negative tax base and taxation under tax category code Z to correct the tax base
  • an invoice note about the tax on used car parts: “The invoice includes XX euros in (value-added) tax on used car parts in accordance with section 10.5 (3) of the VAT Application Ordinance. / Rechnung enthält XX EUR (Umsatz)Steuer auf Altteile gem. Abschn. 10.5 Abs. 3 UStAE.”

How should I indicate credits and invoice corrections?

When creating invoices, you may have to indicate various types of credits or corrections. Electronic invoices make it easier to interpret invoice data because the invoice type can be directly read from field BT-3:

  • Corrected invoice: you want to correct or cancel a submitted invoice. To do this, you must create a credit.

    Code in BT-3: “384” (corrected invoice)

    Note: You must indicate the invoice to be corrected (PRECEDING INVOICE REFERENCE, BG-3).

  • Credit note: Irrespective of previous invoices, the invoice issuer is attributed a credit or voucher. This may be the case where a customer has generated a certain revenue within a given period, qualifying them for a refund or credit.

    Code in BT-3: “381” (credit note)

    Note: In this case, it is not necessary to add another minus sign to the payment total.

  • Self-billed invoice: The recipient of the product or service creates a credit in accordance with section 14 (2) sentence 2 of the VAT Act (Umsatzsteuergesetz, UstG) as an invoice for this product or service.

    Code in BT-3: “389” (self billed invoice)

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