Con­ver­si­on of cash regis­ters: How to treat ari­sing costs for tax pur­po­ses

In the letter dated August 21, 2020, the Federal Minis­try of Finan­ce pro­vi­des infor­ma­ti­on on the costs to be trea­ted for tax pur­po­ses as a result of the first-time imple­men­ta­ti­on of a tech­ni­cal safety device (TSS).

Max Stainer

Max Stai­ner

Sales Mana­ger

In the letter dated August 21, 2020, the German Federal Minis­try of Finan­ce pro­vi­des infor­ma­ti­on on how the costs are to be trea­ted for tax pur­po­ses that are ari­sing from the imple­men­ta­ti­on of the cer­ti­fied tech­ni­cal safety device (TSS).


The fol­lo­wing app­lies to the tax tre­at­ment of the costs of imple­men­ting TSS and the uni­form digi­tal inter­face:


The ongo­ing fees incur­red for cloud TSS are “regu­lar­ly imme­dia­te­ly deduc­tible as ope­ra­ting expen­ses”.


If a TSS con­sists of a USB stick, a memory card or simi­lar, it is an inde­pen­dent eco­no­mic good which cannot be used inde­pendent­ly. The acqui­si­ti­on costs must the­re­fo­re be capi­ta­li­zed and amor­ti­zed over the normal life cycle of three years.

If the TSS is instal­led as hard­ware direc­t­ly in a cash regis­ter, it is a non-inde­pen­dent asset. The expen­ses must the­re­fo­re be capi­ta­li­zed as sub­se­quent acqui­si­ti­on costs of the asset and depre­cia­ted over its remai­ning life cycle.

Costs of imple­men­ta­ti­on

The expen­ses for imple­men­ting the TSS are inci­den­tal acqui­si­ti­on costs of the TSS asset.

Sim­pli­fi­ca­ti­on rule

Besi­des there is a sim­pli­fi­ca­ti­on regu­la­ti­on, that says:

For rea­sons of sim­pli­fi­ca­ti­on, no objec­tion will be raised if the costs for the sub­se­quent initi­al equip­ping of exis­ting cash regis­ters or cash regis­ter sys­tems with a TSS and the costs for the initi­al imple­men­ta­ti­on of the uni­form digi­tal inter­face of an exis­ting elec­tro­nic record­ing system are imme­dia­te­ly deduc­ted in full as ope­ra­ting expen­ses”.

The letter of the BMF can be found on the web­site of the Federal Minis­try of Finan­ce.

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