The Federal Ministry of Finance (BMF) has published its draft for the new of tax simplification Act on February 2, 2011. Bonn. So far, the use of “conventional” memory media, such as modifiable disk and hard drives for storing relevant data was not a violation of the law. Through the realisation of future allowable disk, such as CD-ROM, DVD, and microfilm, in the design of the BMF, widespread alternatives, such as storage area networks, ensuring the immutability and comprehensibility, would be no longer in compliance with the law after current Kenntisstand. The VOI competence center law (CCSR) and taxes has critically discussed the formulation of the BMF for the Unveranderbarkeitsanforderungen and submitted a proposal to the restatement of the law at the Ministry.

The opinion of the CCSR is available for download on. When designing for the tax simplification Act, the Federal Ministry of Finance relies on the existing laws and Regulations, such as the AO, GoBS and GDPdU, the UStG. According to which the storage of content and formatting data of electronic accounting on a disk must be, which does not permit subsequent changes. The question and answers catalogue (questions and answers on the simplification of the electronic invoicing as of July 1, 2011 “, stand: 18.04.2011) goes beyond the previous legal, retention requirements with the specification of technical requirements. Thus, special technical solutions for electronic invoices are required. The current implementation variants in relation to archiving and storage were therefore insufficient. Objective of the VOI competence center tax and law a definition of requirements for the storage of documents according to all legal bases of the commercial and tax law is very helpful for the operators and users. However, these requirements must be consistent and no special requirements may apply for the e-invoices”, says Thorsten Brand Manager the CCSR and consultant for the Zoller & Partner GmbH.