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Amendments to UStG: Retention Periods and Credit Note Liabilities Under BEG IV and JStG 2024

  • The BMF issued a letter on July 8, 2025, detailing legal changes due to the Fourth Bureaucracy Relief Act and the German Annual Tax Act 2024.
  • The retention period for invoices under Section 14b UStG is reduced from ten to eight years.
  • This change applies to invoices whose retention period has not expired by December 31, 2024.
  • For financial institutions, the change applies to invoices whose retention period has not expired by January 1, 2026.
  • Section 26a UStG is amended to align with the new retention period.
  • Retention periods do not expire if documents are relevant for taxes with an unexpired assessment period.
  • Retention periods for VAT records remain at ten years.
  • The German Annual Tax Act 2024 amends Section 14c UStG regarding credit notes.
  • A person may owe incorrectly reported VAT if shown in a credit note to a non-trader.
  • Liability for tax shown in a credit note applies if not immediately objected to, even if not an entrepreneur.
  • Entrepreneurs are liable for tax shown in a credit note for services they are not entitled to show tax for.

Source: hub.kpmg.de

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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