E-invoicing: Specific considerations regarding hospitality receipts
There is often some uncertainty surrounding business meals: does the restaurant bill have to be an e-invoice? In most cases, no. This article explains the specifics.
Introduction
Entertainment expenses offer tax advantages: 70 per cent of reasonable expenditure is deductible as business expenses, whilst input VAT is deductible in full. With e-invoicing, two questions now arise that are often confused – we’ll clarify them for you and handle the tax processing.
A clarification first, as there is a common misconception here:
It is not the case that, from 2025, every hospitality invoice will have to be an e-invoice. The vast majority of restaurant bills are excluded because they fall under an exemption.
There are two aspects to distinguish between:
Firstly, the question of whether the restaurant is required to issue an e-invoice at all.
Secondly, the question of what you need for the business expense deduction – this is where the hospitality receipt comes into play, as newly regulated by the BMF circular of 19 November 2025.
This article addresses both aspects in turn, explains the interplay between e-invoices and hospitality receipts, and clears up common misunderstandings.
Level 1: Does the hospitality receipt have to be an e-invoice?
The first question concerns the restaurant’s obligation to issue e-invoices. And here, the €250 threshold provides relief in most cases.
Restaurant bills are almost always small-value invoices up to €250 gross. Such small amounts are exempt from the e-invoicing obligation – so the restaurant does not have to issue an e-invoice for them. You can find out more about small-value invoices in the following article:
Only when the bill exceeds 250 euros and the transaction is between domestic businesses does the e-invoicing obligation apply to the restaurant – and even then, only after the transitional period applicable to the restaurant has expired.
Nothing changes for a typical business lunch: if the bill is under 250 euros, it remains a standard invoice. An e-invoice only becomes relevant for larger hospitality expenses exceeding 250 euros in business-to-business transactions – such as a large company party or a catering event.
Level 2: What you need for the business expense deduction
The second level is independent of the first: for the tax office to recognise the hospitality expense as a business expense, you need certain supporting documents – regardless of whether the invoice is an e-invoice or not.
The BMF circular dated 19 November 2025 has reorganised these documentation requirements. It applies to hospitality expenses from 1 January 2025 and replaces the previous circular from 2021. The basic requirements have remained essentially the same, but now make a clear distinction based on the amount of the invoice.
The invoice must include: the name and address of the catering establishment, the date of issue, a description of the service provided and the price. For the description of services, details such as ‘Menu 1’, ‘Dish of the Day 2’ or ‘Lunch buffet’ are sufficient; general descriptions such as ‘food and drink’ are not sufficient.
In addition, the tax office requires the date of service – even though this is not a mandatory detail for a small-amount invoice, it is necessary for the deduction of business expenses.
In addition to the details mentioned above, the name of the business providing the service – i.e. your name as the recipient of the service – must appear on the invoice. This constitutes a valid invoice specifying the recipient of the service.
It must also include the other mandatory details required for a complete invoice, such as the restaurant’s tax number or VAT registration number.
In both cases, you will also need a supporting document – the hospitality receipt.
The hospitality receipt as your own supporting document
The invoice alone is not sufficient. To claim the deduction, you must document the reason for and the participants in the hospitality event. This is done via an informal self-issued receipt, which you must draw up and sign promptly.
On the internal receipt, you should record the venue, date, attendees and reason for the hospitality, as well as the amount of the expenses. The more precisely and clearly the reason is described, the more certain the deduction is; brief or unclear details increase the risk that the tax office will refuse the deduction.
If the hospitality invoice is an e-invoice
For larger hospitality expenses exceeding 250 euros in business dealings with companies, the invoice may be an e-invoice. In such cases, it is important to ensure that the e-invoice and your own receipt are clearly linked.
The e-invoice – such as a ZUGFeRD or XRechnung file – is the authoritative invoice document and must be retained in its original format. You should continue to create your own supporting document, stating the reason for the expense and the participants, as a separate document and link it to the e-invoice. You must not alter the structured data of the e-invoice; any additions you make must be included in the separate supporting document.
A practical note from the BMF letter: Any additional tip given may be shown on the machine-generated and electronically recorded invoice. When retaining these documents, the principles of proper bookkeeping must be observed.
Submission to us
For processing, we require both: the hospitality invoice in its original format – in the case of an e-invoice, the structured file – and the corresponding supporting document.
The transfer takes place via the method agreed with us, such as DATEV Unternehmen online or a dedicated upload address. We will cover the process of sending documents to us separately. \[Link zu einem Hilfsartikel] Please ensure that the invoice and supporting document arrive together so that we can correctly allocate the deduction.
Common sources of error
- Assuming that every hospitality expense requires an e-invoice: Restaurant bills up to 250 euros are exempt from the e-invoicing requirement. An e-invoice only becomes relevant for larger amounts in the B2B sector.
- Forgetting the supporting document: Only the invoice is provided. Without a supporting document stating the occasion and attendees, the tax office will not recognise the deduction.
- Reason described too vaguely: The reason is unclear or worded in general terms. This increases the risk that the deduction will be disallowed.
- Mandatory details added by hand: Missing invoice details are written onto the supporting document by hand. This is not sufficient; the details must appear on the invoice itself.
- Altered e-invoice: Notes have been added to the file of an e-invoice for hospitality expenses. The structured data must not be altered; any additions must be made on the supporting document.
- Only the invoice submitted: We only receive the invoice without the supporting document. To claim the deduction, we need both together.
How we work together
When entertaining clients, you collect the invoice and your own receipt; we handle the tax classification and the deduction.
Your tasks:
- Keep the hospitality invoice – in its original format if it is an e-invoice
- Create and sign the supporting document promptly, stating the occasion and attendees
- Submit both the invoice and your own receipt to us via the agreed method
Our tasks:
- Check the business expense deduction and the input VAT deduction
- Classify the supporting documents for tax purposes and post them to the accounts
- Provide support with any queries regarding documentation requirements
We will agree the exact breakdown with you.
Frequently asked questions
Does every hospitality invoice now have to be an e-invoice?
No. Restaurant bills up to 250 euros are exempt from the e-invoicing requirement. An e-invoice is only required for amounts over 250 euros in business-to-business transactions and, following the expiry of the transition period, for restaurant bills.
What has changed as a result of the BMF letter dated 19 November 2025?
It reorganises the documentation requirements for hospitality expenses and aligns them with e-invoicing. It applies to hospitality expenses from 1 January 2025 and makes a clear distinction between bills up to and over 250 euros.
What details must the hospitality invoice contain?
Up to 250 euros: the name and address of the establishment, the date, a description of the service (‘Menu 1’ is sufficient) and the price. For amounts over 250 euros, your name as the recipient of the service must also be included, along with the other mandatory details required for a complete invoice.
Do I still need a hospitality receipt even if I receive an e-invoice?
Yes. You must always document the occasion and attendees on a separate internal record – regardless of whether the invoice is an e-invoice.
Can I write the occasion and attendees on the invoice?
Handwritten additions are not sufficient to fulfil the mandatory details required on the invoice. The occasion and attendees must be recorded on the separate receipt; in any case, you are not permitted to alter an e-invoice.
How much can I claim as a deduction?
70 per cent of reasonable entertainment expenses incurred for business purposes are deductible as business expenses. Input VAT is fully deductible, provided the conditions are met.
How do I submit hospitality receipts to you?
Via the agreed method, usually DATEV Unternehmen online or an upload address. It is important that the invoice and your own receipt are submitted together. \[Link zu einem Hilfsartikel]
Legal notice
This article provides an overview and does not constitute individual advice. The tax treatment of entertainment expenses depends on the individual case; the current legal position applies, in particular the Federal Ministry of Finance (BMF) circular dated 19 November 2025.
If you have any questions regarding your entertainment expense receipts, please contact us directly.
As at: June 2026