Cross-border e-invoicing in the EU: which rules apply and how to send

When a business in one EU Member State invoices a business in another, the invoicing rules of the country where the supply is deemed to take place apply — and where the customer accounts for the VAT under reverse charge, the supplier's own country's rules apply instead (Article 219a of the VAT Directive). Today no national e-invoicing mandate in Germany, France, Belgium or Poland forces a structured invoice onto that cross-border transaction; each mandate stops at its own border. From 1 July 2030 the ViDA directive makes structured e-invoices the basis of EU-wide digital reporting for cross-border B2B supplies. Until then, Peppol is the practical rail when both parties can receive over it.

Which country's invoicing rules apply?

The rules of the Member State in which the supply is deemed to be made — unless the supplier is not established there and the customer is liable for the VAT, in which case the supplier's Member State's rules apply.

Article 219a of the VAT Directive, inserted by Directive 2010/45/EU, states that "invoicing shall be subject to the rules applying in the Member State in which the supply of goods or services is deemed to be made". The exception covers the common B2B case: the supplier has no establishment in the customer's country and the customer is liable for the VAT (reverse charge). Then invoicing follows "the rules applying in the Member State in which the supplier has established his business or has a fixed establishment from which the supply is made". If the customer issues the invoice under self-billing, the first rule governs again.

In practice this means that a German consultancy invoicing a French client for services follows German invoicing rules — Article 219a sends it home because the French client self-assesses the VAT. A Belgian wholesaler shipping goods to Germany as an intra-Community supply follows Belgian rules for the same reason. The place-of-supply rules (Title V of the directive) decide which case you are in; anything beyond the standard patterns requires professional confirmation.

Reverse charge, VAT IDs and the invoice content

A cross-border B2B invoice inside the EU normally carries no VAT, shows both parties' VAT identification numbers and states "Reverse charge" — and the deadline is the 15th day of the month after the chargeable event.

Article 226 of the VAT Directive lists the mandatory content. Point 4 requires the customer's VAT identification number where the customer is liable for the VAT or receives an intra-Community supply of goods; point 11a requires, "where the customer is liable for the payment of the VAT, the mention 'Reverse charge'". Article 222 sets the issuing deadline for intra-Community supplies of goods and for services on which the customer is liable: "no later than on the fifteenth day of the month following that in which the chargeable event occurs".

The customer's VAT ID is the evidence that the buyer is a taxable person in another Member State, which is what allows the zero rate or the reverse charge. Checking it in VIES before issuing is the ordinary diligence expected of a seller — see the free VAT ID checker. If the ID is invalid, the supply may have to be treated as one to a non-taxable person; that decision requires professional confirmation.

Intra-Community supply of goods (B2B)

Goods move from one Member State to another. Supplier invoices without VAT, both VAT IDs on the invoice, the customer accounts for acquisition VAT. Supplier reports in its recapitulative statement.

B2B services under the general rule

Place of supply is where the customer is established (Article 44). Supplier invoices without VAT; customer self-assesses under Article 196. Invoice states "Reverse charge".

Services with a special place-of-supply rule

Land-related services, events, restaurant services and others follow their own rule and may be taxed in the supplier's or a third country. Requires professional confirmation.

Do the national e-invoicing mandates reach across the border?

No. Each of the four national mandates is scoped to domestic transactions, so a cross-border invoice between two EU businesses is today governed by the ordinary VAT rules, not by a structured-format obligation.

The consequence for a seller is asymmetric. Selling from Germany to France, you may send a PDF or a structured file as you and the customer agree; the French customer has no e-invoice to receive through its platform but must e-report the purchase. Selling from Poland to Belgium, the Polish seller must still put the invoice through KSeF because the issuer is Polish, and then deliver it to the Belgian customer outside the system. The B2B versus B2G page sets out the mandates in full.

Why Peppol is the cross-border rail

Peppol is the only network among the four countries that works the same way on both sides of a border: one connection to an accredited access point reaches any registered receiver anywhere in the network.

OpenPeppol describes the network as a "ready-to-use, scalable, both domestic and cross border, four-corner model". The sender's access point looks up the receiver's identifier through the SML and SMP, learns which document types the receiver accepts, and delivers the file to the receiver's access point. The Belgian authority adds a useful legal point: "Registration on the Peppol network is considered as an agreement to receive structured electronic invoices (at least in Peppol-BIS format)" — which matters because Article 232 of the VAT Directive still makes the use of an electronic invoice "subject to acceptance by the recipient" until ViDA changes it.

Two limits apply. The receiver must actually be registered — a French or German company without a Peppol identifier cannot be reached, and Germany in particular has no default network. And the document must be one the receiver accepts: a German company registered for XRechnung UBL will not accept a Peppol BIS Billing 3.0 invoice unless it has published that capability. Both are lookups, not guesses; see Peppol identifiers and sending and receiving over Peppol, and compare Peppol with the national networks.

What ViDA changes on 1 July 2030

From 1 July 2030 cross-border B2B transactions between EU businesses fall under digital reporting requirements built on structured e-invoices, according to the Commission's ViDA page; the directive's recitals set a 10-day issuing deadline for those invoices and the standard-compliant structured format as the norm.

Council Directive (EU) 2025/516 entered into force on 14 April 2025. The parts that matter for cross-border invoicing are the 2030 provisions: the transaction-by-transaction reporting of intra-Community supplies replaces the periodic recapitulative statement, the invoice becomes the data carrier for that reporting, and an e-invoice complying with the European standard no longer depends on the recipient's consent. National real-time reporting systems must align with the EU model by 1 January 2035. The EU requirements page tabulates the whole ViDA timeline and the mandate timeline places it next to the national dates.

Three worked examples

The examples use the rules above; the VAT conclusions are the standard outcome for the stated facts.

Germany → France: software consultancy

1. Place of supply: France (customer's establishment, Article 44). Customer liable under Article 196.
2. Invoicing rules: German (Article 219a(2), supplier not established in France).
3. Invoice: no German VAT, both VAT IDs, "Reverse charge" (in German practice "Steuerschuldnerschaft des Leistungsempfängers"), issued by the 15th of the following month.
4. Format: no mandate on either side. An XRechnung or ZUGFeRD file is a valid EN 16931 invoice; the French customer's platform may or may not be able to receive it over Peppol. Agree the channel with the customer. The French customer e-reports the purchase.

Belgium → Germany: goods

1. Intra-Community supply from Belgium; the German customer accounts for acquisition VAT.
2. Invoicing rules: Belgian. Belgian mandate does not apply (supply taxed in Germany).
3. Format and channel: the Belgian seller can send a Peppol BIS Billing 3.0 invoice if the German buyer has a Peppol identifier; otherwise the buyer's email inbox — which the BMF FAQ says suffices for receiving — and a ZUGFeRD or UBL file. Both VAT IDs on the invoice, seller files the recapitulative statement.

Poland → Belgium: services

1. Place of supply: Belgium. Belgian customer self-assesses.
2. Invoicing rules: Polish. Because the issuer has its seat in Poland, the invoice must be issued in KSeF from the issuer's mandate date (1 February 2026 for the largest taxpayers, 1 April 2026 for the others).
3. Delivery: KSeF does not deliver to a foreign buyer. The seller sends the invoice image or XML in the agreed way, marked with the KSeF number and QR verification code. The Belgian customer may also accept a Peppol BIS invoice over Peppol if the seller's provider offers it; that does not replace the KSeF submission.

How KRONENWERK handles this

KRONENWERK derives a tax verdict per invoice from the seller's country, the buyer's country, the buyer's business status and the kind of supply, checks the buyer's VAT ID against VIES at issuance, and stores the verdict with the invoice.

• Tax verdict at issuance — standard, zero-rated, exempt, reverse charge, outside scope, or "requires input" / "requires professional confirmation" — never guessed. VIES check of the buyer VAT ID at issuance. SUPPORTED
• Structured formats per seller country: XRechnung and ZUGFeRD (Germany), Factur-X (France), Peppol BIS Billing 3.0 UBL (Belgium), FA(3) (Poland); multi-currency and multi-company for groups with entities in several countries — see several companies, several currencies. SUPPORTED
• Cross-border delivery over Peppol: KRONENWERK sends and receives over Peppol through an accredited access point provider (Storecove) once the company is connected in Settings → Delivery. KRONENWERK is not itself a Peppol access point. SUPPORTED WITH LIMITATIONS
• French transmission through an approved platform NOT YET READY; KSeF submission for Polish issuers NOT YET READY (built, not yet used against the production KSeF).
• Cross-border reporting to a tax authority (recapitulative statements, French e-reporting, the 2030 ViDA reports): KRONENWERK does not file or transmit VAT reports. The verdict stored with each invoice gives your adviser the facts. REQUIRES PROFESSIONAL CONFIRMATION

More on the product at e-invoicing in KRONENWERK; back to the Europe hub.