1. Introduction: From PDF to Structured Invoices
With the introduction of mandatory e-invoicing for domestic B2B transactions as of January 1, 2025, electronic invoice processing has gained substantial importance. While simple PDF invoices were previously sufficient, structured e-invoices (e.g., in XML format) are now at the center of attention. This development has a direct impact on input VAT deduction.
Although the legal requirements for input VAT deduction remain unchanged, the decisive factor is shifting: relevant invoice data must now be derived primarily from the structured dataset rather than from a visually readable document.
2. New Requirements for Input VAT Deduction
In principle, the requirements for input VAT deduction remain the same. An invoice must include key information such as the supplier, recipient, description of the supply, consideration, and VAT amount.
However, in the context of e-invoicing, the critical question is where this information must be correctly stated. According to current understanding, the structured dataset (e.g., XML) is legally decisive, while any visual representation (e.g., PDF) serves only a supplementary purpose.
For businesses, this means that errors in the structured data can jeopardize input VAT deduction—even if the visual invoice appears correct.
3. Typical Risks in Practice
Incorrect or incomplete XML data
One of the main risks lies in inaccurate structured invoice data. If mandatory information is missing or incorrect in the XML dataset, input VAT deduction may be denied.
Inconsistencies between XML and PDF
In practice, discrepancies between structured data and visual representations are common. However, the structured dataset prevails. Businesses therefore risk relying on visually correct but legally irrelevant information.
Insufficient system adjustments
Many ERP and accounting systems are not yet fully adapted to process structured e-invoices. Faulty interfaces or missing validation mechanisms can result in incorrect data being processed unnoticed.
Lack of validation processes
Traditional visual invoice checks are no longer sufficient. E-invoicing requires additional technical validation procedures. Companies that fail to implement automated checks significantly increase their risk exposure.
4. Practical Recommendations for Businesses
To mitigate risks related to input VAT deduction, businesses should take proactive measures. In particular, implementing systems for the automated validation of structured invoice data is essential.
Internal processes should also be adapted to ensure that not only the visual invoice but also the underlying data is reviewed. Close coordination between tax and IT departments is crucial in this regard.
In addition, companies should ensure proper archiving of incoming invoices, including the complete structured dataset. This is essential for demonstrating compliance during tax audits.
5. Conclusion
The introduction of e-invoicing marks a paradigm shift in input VAT deduction. The focus is no longer on visually reviewing invoices but on ensuring the accuracy and integrity of structured data.
Businesses that fail to adapt their systems and processes in time risk losing their right to input VAT deduction. Early engagement with the new requirements is therefore essential to minimize tax risks and fully benefit from digitalization.
