Expert knowledge for digital decisions
For which invoices does the e-invoice obligation not apply?
Short answer
The Exceptions
| Case | Recorded? |
|---|---|
| Invoice to private individual (B2C) | No |
| Small-value invoice up to 250 Euro | No |
| Travel tickets | No |
| Certain tax-exempt transactions under § 4 UStG | No |
| Issuance by small businesses (§ 19 UStG) | No |
| Invoice to a foreign company | Not subject to the German obligation |
| Invoice between domestic companies | Yes |
What the Exceptions Do Not Mean
No prohibition. You may also issue electronic invoices in exceptional cases – often it is even simpler to treat everything the same way, rather than maintaining two separate processes.
No exemption from receiving. Even those who are not required to issue invoices themselves – such as small businesses – must be able to receive e-invoices. This distinction is most frequently misunderstood.
Edge Cases to Consider
- Mixed invoices containing both tax-exempt and taxable items
- Recurring invoices such as rent, where a contract serves as an invoice
- Down payments and final invoices with offsetting
These cases should be clarified with a tax advisor before switching over.
Practical Advice
Operating two parallel systems – electronic and paper – is more expensive in the long run than one. Those who are switching over should check whether the exceptions truly justify the special approach.
This text does not replace tax advice.
Key facts
- Small-value threshold
- 250 Euro
- Most common misunderstanding
- Exemption from issuing does not apply to receiving
Sources
All external claims are backed by traceable sources.-
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Umsatzsteuergesetz (UStG) Bundesministerium der Justiz