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Invoicing in a foreign currency in Germany: which exchange rate applies? (ECB, DATEV, OSS)

An invoice may be issued entirely in a foreign currency, as long as the VAT is also stated in the currency of the country where the sale takes place, so in euros for German sales (Art. 230 of the EU VAT Directive). By default, Rechnungskit calculates this EUR amount at the ECB reference rate on the issue date or, once your tax office (Finanzamt) has granted permission, at the official prior-month rate published by the Federal Ministry of Finance (BMF) (section 16.4(2) UStAE). Rechnungskit states the amount in structured form in the e-invoice (BT-6/BT-111) and freezes the rate, rate date and rate source on the document so they cannot change.

Can I invoice in a foreign currency?

Yes. Your invoice may be issued entirely in CHF, USD, GBP or another currency. The condition is in the EU VAT Directive: the VAT must be stated in the currency of the member state where the sale takes place (Art. 230 of the VAT Directive, German version). For a German sale, that means the VAT amount must also appear in euros on the invoice. The German VAT Act (UStG) does not repeat this requirement explicitly; the conversion follows § 16(6) UStG (German).

Rechnungskit handles exactly that for you. Invoices can be issued in EUR and in CHF, USD, GBP, SEK, DKK, NOK, PLN, CZK and CAD, and the EUR VAT amount is added automatically.

Which rate applies?

Rechnungskit converts at the ECB reference rate, the fixing the European Central Bank publishes every day. For the EUR amount on the invoice, it uses the last rate published on the issue date.

The rate is not fetched again each time the invoice is opened. It is frozen when the invoice is issued, and the rate, rate date and rate source become a fixed part of the document. If the customer pays weeks later at a different rate, the document stays as it is. For VAT purposes, exchange rate changes between the supply and the receipt of payment are disregarded (section 16.4(1) sentence 2 UStAE, German).

Example · Invoice in USD
The issue-date rate stays on the document, even if payment comes later
  1. Issue dateInvoice in USD with the VAT amount in EURConverted at the last ECB reference rate published that dayRate frozen
  2. Weeks laterCustomer pays at a different rateDisregarded for VAT purposes
  3. On the documentRate, rate date and rate sourceUnchanged, exactly as on the issue date
The rate is not fetched again each time; it is fixed when the invoice is issued (section 16.4 UStAE).

In the e-invoice (BT-6/BT-111)

For a foreign currency invoice, the e-invoice (ZUGFeRD 2.5 / EN 16931) uses separate currency fields:

  • BT-5, invoice currency: the actual currency of the document (for example USD).
  • BT-6, VAT accounting currency: EUR, because German VAT has to be stated in euros.
  • BT-111, VAT total in accounting currency: the EUR amount calculated at the ECB rate.

This is the structure the standard provides for documents whose VAT currency differs from the invoice currency. The invoice stays correct as machine-readable data and passes format validation.

DATEV: rate and EUR base

DATEV is the accounting software most German tax advisors use, and the DATEV export is how your bookings reach them. In the export, every foreign currency booking carries the full conversion:

Field Content
Invoice currency e.g. USD
Rate the ECB rate used (indirect quotation)
Base amount the amount in EUR
Base amount currency EUR

Your tax advisor can follow the conversion without gaps and, if needed, switch to the official monthly rate without missing any information.

OSS: the quarter-end rate

If you sell to consumers in the EU and report through the OSS scheme (One-Stop Shop, the EU-wide VAT return for cross-border B2C sales), a stricter rule fixed by law applies. OSS sales in a foreign currency are converted at the ECB rate of the last day of the reporting quarter; if there is no rate for that day, the next day's rate applies (§ 16(6) sentences 4 and 5 UStG, German). The tax authorities explicitly rule out a monthly average rate here (section 18j.1(4) UStAE, German), and the law does not provide for your payment provider's rates either.

Rechnungskit applies exactly this quarter-end rate. While the quarter is still running, the preview shows a provisional rate, and the return can only be locked once the final quarter rate is available. The rate used is documented in the locked return.

ECB daily rate or BMF monthly rate?

One point to keep in mind: which rate you may use for the tax is governed by § 16(6) UStG (German), not by § 14 UStG. The daily rate on the invoice is therefore not automatically the rate you use when you file the tax.

For the VAT pre-return (Umsatzsteuer-Voranmeldung), the legal default is the monthly average rate that the BMF publishes for the month of the supply (§ 16(6) sentence 1 UStG, German). You may only use a daily rate, such as the ECB reference rate, if your tax office permits it (§ 16(6) sentence 3 UStG, German). As a simplification, the tax office can also permit you to use the average rate of the previous month consistently, which is already known when you invoice (section 16.4(2) UStAE, German).

Rechnungskit supports both methods, with the ECB daily rate as the default. Without permission, that rate is not the legal standard for the pre-return, so your tax advisor converts to the monthly rate. If you have permission for the prior-month rate, go to Settings → DATEV and switch to the BMF prior-month rate with one click, confirming that you have the permission. From then on, Rechnungskit uses the previous month's average rate. The BMF monthly rates are synced automatically and rounded to four decimal places, so the value matches the officially published rate. Which method applies to you is something to settle with your tax advisor; the DATEV export provides the basis (rate, EUR base and rate date for each booking).

OSS is unaffected: the law prescribes the quarter-end rate there, and Rechnungskit applies it directly, whichever method you chose for invoices. More under foreign currencies in detail.

Three purposes, three rates
Which exchange rate applies to what?
Invoice
VAT amount in EUR on the document. With permission, you switch to the BMF prior-month rate.
RateECB daily rate
VAT pre-return
Legal default. ECB daily rate or BMF prior-month rate only with your tax office's permission.
RateBMF monthly rate
OSS return
Fixed by law; monthly average rates are excluded
RateECB quarter-end rate
For the pre-return and OSS, § 16(6) UStG sets the rate. Which method applies to you is something to settle with your tax advisor.

How it works in Rechnungskit

You do not have to convert anything or maintain a rate table:

  1. Rates sync automatically. Rechnungskit syncs the ECB reference rates daily and keeps the history, so the correct daily rate is available for older documents too.
  2. The document is created in the order currency. An order in USD becomes an invoice in USD, with the VAT amount in EUR calculated at the ECB rate of the issue date and frozen.
  3. The export is ready. DATEV gets the rate and the EUR base, and OSS converts automatically at the quarter-end rate. Your tax advisor decides on the final rate method.

Payments in an unsupported currency (for example JPY), or in a currency that does not match the order, are never invoiced automatically. They become a task to resolve, so no document is created with a questionable rate.

Read more about the EU scheme under OSS return and about the tamper-proof export under DATEV export.

FAQ

Yes. The amounts on the invoice may be in any currency, including entirely in CHF, USD or GBP. The VAT, however, must also be stated in the currency of the member state where the sale takes place, so in euros for German sales (Art. 230 of the VAT Directive, German version).
Read more
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Rechnungskit is not a tax advisory or law firm. This article explains general principles and does not replace advice from a tax advisor (Steuerberater, § 5 StBerG) or a lawyer (§ 3 RDG). Rechnungskit is built for businesses based in Germany and prepares documents, tax rates and bookings automatically. How your specific case is treated remains your decision, ideally together with your tax advisor or a lawyer.

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