Core Summary: Key Changes in the 2025 Draft
1. End of Paper Proofs for Non-EU Entrepreneurs
While EU-based companies have been digitized since 2010, non-EU entrepreneurs were previously required to submit original physical invoices. The new draft ordinance eliminates this media disruption:
- Mandatory Upload: Invoices and import receipts must now be uploaded to the BZSt online portal.
- Storage Media: Submission via USB/storage media is only permitted in "exceptional cases" (e.g., when file sizes exceed capacity limits).
- Originals: Submitting physical originals will now only be allowed in "justified individual cases." Applications submitted with paper receipts may be rejected in the future.
2. Electronic Notification of Tax Notices
The procedure for receiving refund notices is also moving online, with significant differences depending on the applicant's location:
- For EU-based companies: Electronic notification via the BZSt portal becomes available from January 1, 2026, provided the user has a portal account. Postal notification remains an option upon request.
- For non-EU companies: Electronic data retrieval is becoming the mandatory standard. Postal notification will only be granted upon specific application to avoid "undue hardship."
3. Procedural Consequences
The switch to electronic notification is not just a technical change—it affects legal deadlines. The time limit for filing appeals (objections) is calculated differently for digital retrieval compared to traditional postal delivery.