How does e-invoice work for a VAT group registered under § 4b?
Short answer
For group registration under § 4b, transactions with third parties must be distinguished from internal transactions between members of the group. Supplies between members of the same VAT group may fall outside the scope of VAT and may not create an obligation to issue an invoice under § 72. If members exchange documents voluntarily through Peppol, they must still comply with the technical rules for the participant ID, tax category O and the prohibition on stating VAT identifiers under rule BR-O-02.
VAT group
Members act separately in the VAT regime vis-à-vis third parties.
Routing
The Participant ID can be based on the TIN of a specific member.
Joint registration
The tax field cannot be mixed with the technical address.
Without VAT ID at O
In the case of an out-of-scope document, the VAT identifiers of the parties will not be entered.
Conclusion
In the case of group VAT, the tax status of the group, the technical direction through the VAT number and Peppol rules for documents outside the subject of VAT must be separated; mechanical copying of the VAT number into all fields leads to errors.
Not legal advice.