E-Invoicing for Landlords in Germany: Rent, Service Charges and VAT

E-invoicing for landlords in Germany applies only to taxable lets to German businesses: commercial leases where the landlord opted into VAT under § 9 UStG, parking spaces and short-term accommodation. Residential lets that are VAT-exempt under § 4 No. 12 UStG are out of scope. All landlords who are businesses for VAT purposes have had to accept e-invoices since 1 January 2025.

This guide is for international property owners, funds and asset managers with German real estate, and for English-speaking private landlords in Germany. After reading it, you can sort each lease into a category and know which invoices must be structured, and from when. The general deadlines are in our guide to the Germany e-invoicing mandate.

Does the e-invoicing mandate apply to landlords?

The rule is in Section 14(2) sentence 2 No. 1 of the German VAT Act (§ 14 UStG). An invoice for a supply "to another business for its business" must be an e-invoice if both the supplier and the customer are established in Germany. The sentence before it limits the rule: the duty to invoice applies only if the supply is not exempt under § 4 Nos. 8 to 29 UStG.

For landlords, VAT therefore decides the invoice format:

• § 4 No. 12(a) UStG exempts the letting and leasing of land and buildings. This covers flats, houses, offices and shops, unless the landlord opts into VAT.
• § 4 No. 12 sentence 2 UStG excludes some supplies from the exemption: rooms held for the short-term accommodation of guests, spaces for parking vehicles, short-term letting on campsites and operating equipment (Betriebsvorrichtungen).
• § 9(1) UStG allows the landlord to waive the exemption (VAT option, Option zur Umsatzsteuer) when letting to a business for its business. Under § 9(2) UStG this is allowed for property only if the tenant uses it exclusively for supplies that do not exclude input VAT deduction (Vorsteuerabzug).

A VAT-exempt residential let creates no e-invoice duty. A landlord who opted into VAT on a lease to a bakery, an engineering office or a retailer issues invoices for a taxable B2B supply. Those invoices fall under the e-invoicing mandate, with the transition periods of § 27(38) UStG. A medical practice is a typical case where the option fails, because medical treatment is exempt under § 4 No. 14 UStG.

Which lets are in scope?

Two boundaries matter in practice. Whether a parking space let in the same contract as a flat counts as part of the exempt residential rent or as a separate taxable supply is a question to settle with a German tax adviser before you change any invoices. The reduced 7 % rate does not apply, under § 12(2) No. 11 sentence 2 UStG, to services that do not directly serve the letting, such as breakfast.

The other exemptions from the mandate, such as small-amount invoices, are covered in our guide to German e-invoicing exemptions.

What if the owner or the tenant is abroad?

This is the first question for international owners. The mandate applies only when both parties are established in Germany (§ 14(2) sentence 2 No. 1 UStG). The law defines "established" as having in Germany a registered office, the place of management, a fixed establishment (Betriebsstätte) involved in the supply, or, failing a registered office, a residence or habitual abode.

Whether a let property alone creates a fixed establishment depends on the facts, such as staff or management on site. Clarify it with a German tax adviser.

Receiving and issuing: what landlords must do

Why must a residential-only landlord receive e-invoices? Letting property for income makes the landlord a business under § 2 UStG. In its letter of 15 October 2024 (para. 17), the Federal Ministry of Finance (BMF) names the "landlord of a flat" as a recipient to whom the supplier's e-invoice duty applies. The roofer who repairs the building may therefore send an XRechnung or a ZUGFeRD file without asking first. An e-mail inbox is enough (para. 40). Our guide on how to receive e-invoices in Germany covers opening and storing the files.

The lease as a recurring invoice

Many landlords use the lease agreement, with VAT shown, as the invoice. That still works, but not on paper or as a PDF once an e-invoice is required. The BMF letter of 15 October 2024 covers continuing obligations in three paragraphs:

1. Para. 44: a contract can count as an invoice if it contains the details required by §§ 14, 14a UStG. If an e-invoice is required, the contract can be included as an attachment to the e-invoice.
2. Para. 45: for a lease, it is enough to issue an e-invoice once, for the first period, with the contract attached or with content that makes clear it is a recurring invoice (Dauerrechnung). A new e-invoice is needed only when a mandatory detail changes, "for example, a rent increase".
3. Para. 46: recurring invoices issued as other invoices (paper or PDF) before 1 January 2027 do not need an additional e-invoice as long as the invoice details do not change.

For a running commercial lease with the VAT option, the existing paper lease keeps working until the rent, the VAT rate, the parties or another mandatory detail changes. From the first such change after your transition period ends, you issue an e-invoice. Typical triggers are an index adjustment, a new tenant or a new billing address.

Service charges and contractor invoices

Service charge statements (Nebenkostenabrechnung). A statement is an invoice if it bills a supply (§ 14(1) UStG). Whether it must be an e-invoice follows the same test as the rent: a taxable supply to a business established in Germany? For a shop lease with the VAT option and VAT on the service charges, yes, after the transition periods. For a flat let to a private tenant, paper or PDF remains fine.

Contractor invoices. Here the landlord is the recipient. A landlord who opted into VAT needs a proper invoice to deduct input VAT. Where the supplier must issue an e-invoice, only an e-invoice meets the requirements of §§ 14, 14a UStG (BMF letter of 15 October 2024, para. 55). A PDF does not.

Mixed invoices. In the same letter (para. 17), the BMF states that the mandate also applies when only part of the invoiced supplies is subject to it, for example partly taxable and partly exempt supplies. A landlord who lets a shop and a flat to the same business and bills both together issues the whole invoice as an e-invoice.

Worked example: a mixed-use building

The fictitious Example Property GbR owns a building with four flats, one shop and six parking spaces. All amounts are annual net figures for 2026.

What follows:

1. Exempt rent does not count. § 19(2) No. 1 UStG deducts supplies exempt under § 4 Nos. 11 to 29 UStG. The EUR 43,200 of residential rent therefore adds nothing to total turnover (Gesamtumsatz). The privately let parking spaces do count, even though they need no e-invoice.
2. The 2027 transition applies. At EUR 28,320, the GbR is far below EUR 800,000. For shop rent in 2027 it may still use paper or, with the bakery's consent, PDF (§ 27(38) No. 2 UStG). The EUR 800,000 rule for 2027 is explained in detail in a separate guide.
3. E-invoice to the bakery from January 2028. The simplest route is one recurring e-invoice under para. 45 for the shop and the parking spaces. If the rent changes during 2028, a new e-invoice is needed from then on.
4. Small-business rule? Total turnover is above EUR 25,000, so the GbR is not a small business (Kleinunternehmer) in 2027 and cannot rely on § 34a UStDV. The Kleinunternehmer calculator runs other scenarios.

Special cases

Small landlords. A landlord of a holiday flat or parking spaces whose total turnover stays below EUR 25,000 in the prior year and EUR 100,000 in the current year is a small business under § 19 UStG. § 34a UStDV allows such invoices to be sent as other invoices at any time. Receiving e-invoices is still required. See our guide on e-invoicing for small businesses.

Property managers (Hausverwaltung). The management fee billed to the owner is a taxable supply to a business. It must be an e-invoice after the transition periods, even if the owner lets only VAT-exempt flats.

90-day checklist

How to check and create landlord e-invoices with docutools.pro

1. Check contractor and utility invoices in the XRechnung viewer. Upload the XML file and read the invoice number, parties, totals, line items and VAT rate in the "Extracted data" table. The file is sent to our server and checked the way the KoSIT validator does (configuration 2026-08-31). The free plan covers two uploads a day up to 500 KB; the Pro plan removes these limits.
2. If the invoice arrives as a ZUGFeRD PDF, first take out the XML with the ZUGFeRD extractor. It runs in your browser.
3. Before you send the recurring invoice to a commercial tenant, go through the mandatory details in the German invoice requirements checker with "Checklist" and "Full invoice (> €250 gross)". It does not check arithmetic or VAT rates.
4. Build the e-invoice in the XRechnung generator: company data, one line item such as "Rent, ground-floor shop, monthly from 1 Jan 2028" at 19 %, and export as "XRechnung XML" or "ZUGFeRD PDF". The generator has no separate field for the service period and cannot embed the lease as an attachment, so state the period in the line description.

More guides on deadlines and sectors are in our e-invoicing mandate guides.

Sources

• § 4 No. 12 UStG (exemption for letting) (opens in a new tab) and § 9 UStG (VAT option) (opens in a new tab)
• § 14 UStG (issuing invoices) (opens in a new tab) and § 27(38) UStG (transition rules) (opens in a new tab)
• § 12(2) No. 11 UStG (opens in a new tab), § 19 UStG (opens in a new tab), § 34a UStDV (opens in a new tab)
• BMF letter of 15 October 2024, BStBl I p. 1320 (IHK copy, German) (opens in a new tab), paras. 17, 40, 44 to 46, 55, 62 to 65. It was supplemented by the BMF letters of 15 October 2025 and 15 October 2026: BMF letter of 15 October 2025 (opens in a new tab)

Last reviewed: October 2026

This article is general information, not tax or legal advice.