Implementing the domestic e-invoicing mandate will be one of the key priorities until the end of the year. The first transitional arrangement expires on 31 December 2026, while many practical questions remain unresolved. In some respects, the requirements of the CEN standard have proved to be a rather rigid framework. On 15 October 2026, the Federal Ministry of Finance therefore published a further letter addressing pressing outstanding issues. Our newsletter summarises the key takeaways.

The debate over the effect of a retrospective invoice correction in intra-community triangular transactions is coming to an end after its second round. The General Court has made it unequivocally clear that an invoice correction in the context of triangular transactions has no effect, either retrospectively or presently. It thus remains faithful to the line taken by the ECJ in the Luxury Trust Automobile case. Failed triangular transactions cannot be healed. Accurate identification and clear invoicing therefore remain mandatory!

In recent years, the European Court of Justice and the German Federal Fiscal Court (BFH) have clarified a number of fundamental issues concerning the German VAT grouping regime. At present, the VAT Act is set to be amended by the Annual Tax Act 2026, most notably through the introduction of a declaration-based procedure. In a recent judgement, the BFH addressed what may appear to be a comparatively “minor” issue relating to financial integration. In doing so, it continues its recent shift in case law. According to the Court, financial integration may exist even where, despite a majority shareholding, the controlling company does not possess the qualified majority required for shareholder resolutions.