By the end of January 2026 the change has arrived in practice: the tax authorities have made international invoicing noticeably easier. Certain mandatory VAT details may now appear on invoices in Germany in other official EU languages as well — in English in particular — provided the terms are unambiguous and in line with the directive. The basis is the amendment of the VAT Application Decree (UStAE) by the BMF circular of 17 September 2025.
Germany is thereby responding to the reality of international billing systems (ERP), standardised group invoices and cross-border supply relationships — and reducing a common practical risk to the input VAT deduction.
Where the friction was
Invoices still have to meet the formal requirements of § 14/§ 14a UStG and of Article 226 of the VAT Directive. In practice, however, exact German wording was long insisted on for the notes that matter most in an audit — above all for:
- reverse charge cases (where the recipient accounts for the tax)
- self-billing
- the margin scheme (for travel services, second-hand goods, works of art, collectors’ items and antiques, for instance)
With international invoice layouts in particular, that regularly led to translation errors, inconsistencies between countries and, in the worst case, formal objections in audits.
What the BMF now makes clear
The BMF makes clear that for certain invoice details, wording customary in other official EU languages for the corresponding details under Article 226 of the VAT Directive may be used in place of German terms. The UStAE has also been extended by an annex listing the permissible terms.
- The principles apply to all open cases.
- An additional German translation is in principle not required for the terms set out in the list, provided the detail is clear and correct.
Permissible terms in practice
| English wording | German equivalent |
|---|---|
| Self-billing | Gutschrift |
| Reverse charge | Steuerschuldnerschaft des Leistungsempfängers |
| Margin scheme – Travel agents | Sonderregelung für Reisebüros |
| Margin scheme – Second-hand goods | Gebrauchtwarenregelung |
| Margin scheme – Works of art | Kunstgegenstände – besonderes Verfahren |
| Margin scheme – Collectors’ items and antiques | Sammlungsstücke & Antiquitäten – besonderes Verfahren |
Who benefits
For companies operating internationally the clarification is an operational gain — particularly for:
- foreign companies invoicing in Germany
- e-commerce arrangements and platform models (the OSS environment included)
- multinational groups with English-language ERP standards
- cross-border B2B services and intra-Community supplies
- companies applying the margin scheme or other special arrangements
In concrete terms that means:
- fewer translation and formatting errors in sensitive mandatory details
- better system compatibility (ERP and e-invoicing templates)
- a lower risk of invoice corrections and process loops
Where the limits are
The new openness on language is not a free pass. The input VAT deduction still depends on an invoice that is correct in form and in substance. Risks arise in particular where:
- a term does not come from the permissible list or is ambiguous
- the VAT treatment is applied incorrectly (reverse charge without the conditions being met, for instance)
- other mandatory details are missing or the evidence is inadequate
In short: a foreign language is permissible — substantive accuracy remains essential.
Checklist for finance, accounting and ERP
- Review invoice templates: where are the reverse charge, self-billing and margin notes output?
- Tie the list of terms to the UStAE annex (no “free” translations).
- Harmonise ERP rules (tax codes, country logic, text blocks) consistently.
- Strengthen master data governance (customer/supplier, place of supply, VAT ID, type of supply).
- Define review paths: who decides in special cases, who documents the VAT treatment?