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On 1 July 2025, the Federal Ministry of Finance (BMF) published a letter on the requirements for the zero-rating of export supplies. The BMF has once again clarified the guidelines on the relevant case law of the ECJ, mainly in structural terms and without any significant practical implications. The only specific changes relate to the proof of the zero-rating for export supplies in non-commercial travel. However, developments in the area of non-commercial travel are not particularly satisfactory, especially in comparison with other EU member states.
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In the new version of the GoBD (principles for the proper keeping and storage of books, records and documents in electronic form and for data access), which entered into force on 14 July 2025, the Federal Ministry of Finance is once again adapting the GoBD to legal changes and technical developments. Taxable persons should check whether changes to their document management system and invoicing processes are necessary. At the same time, businesses must create and maintain audit-proof and up-to-date procedural documentation in order to demonstrate compliance with the GoBD. This brings procedural documentation again into the focus of the German tax authorities.
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The Distance Learning Protection Act is currently the talk of the coaching industry. On the one hand, the Federal Court of Justice (BGH) has now ruled on fundamental questions of application. Among other things, providers must ensure that their courses are, even for commercial participants (“B2B”), approved if they do not want to risk having to refund the full course fee. On the other hand, the German tax authorities want to tie the VAT exemption to said approval in the digital education sector.
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