Invoice Retention Requirements by Country: A Global Guide

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Tax & Compliancerecord retentioncross-border complianceinternational tax
Invoice Retention Requirements by Country: A Global Guide

Article Summary

Compare invoice retention periods across 14 countries. Covers clock-start rules, digital storage acceptance, extension triggers, and cross-border guidance.

Invoice retention requirements vary by country, typically ranging from 3 to 10 years. The United States requires 3 to 7 years depending on circumstances, Canada and the United Kingdom require 6 years, Germany and France require 10 years, and Australia requires 5 years. When operating across borders, retain invoices for the longest applicable period.

This guide provides a structured reference for invoice retention requirements by country, covering 14 jurisdictions that represent the most common operating environments for multinational finance teams. Here is what you will find inside:

  • A quick-reference comparison table showing retention periods, statutory bases, and penalty context for all 14 countries at a glance
  • When the retention clock starts in each jurisdiction, since the trigger date differs between countries and directly affects how long you actually need to keep records
  • Which countries accept electronic-only invoice storage and the specific conditions attached to digital retention
  • Circumstances that extend the standard retention period, including audits, disputes, and fraud investigations
  • Practical cross-border guidance for businesses managing financial document retention periods across multiple jurisdictions simultaneously
  • Common compliance mistakes that lead to penalties, and how to avoid them

Whether you need to verify how long to keep invoices globally for a specific subsidiary or build a unified retention policy across your entire organization, the comparison table in the next section is the best place to start.


Invoice Retention Periods by Country: Quick-Reference Table

The table below covers 14 major jurisdictions and their standard invoice retention requirements. According to a global survey of accounting record retention laws across 200 jurisdictions by the ARMA International Educational Foundation, 10 years is the most commonly encountered retention requirement worldwide, with national accounting laws specifying periods ranging from 3 years to more than 10 years and tax law retention periods ranging from 2 years to 10 years.

CountryStandard PeriodClock StartsDigital StorageKey Authority
United States3-7 yearsFrom date tax return is filedAcceptedIRS
Canada6 yearsFrom end of tax yearAcceptedCRA
United Kingdom6 yearsFrom end of accounting periodAcceptedHMRC
Germany10 yearsFrom end of calendar yearAccepted (conditions)Bundeszentralamt fur Steuern
France10 years (fiscal) / 6 years (commercial)From end of fiscal yearMandatory (2026)Direction Generale des Finances Publiques
Italy10 years (civil code) / 5 years (tax)From date of last entry / from filingMandatoryAgenzia delle Entrate
Netherlands7 years (10 for immovable property)From end of fiscal yearAccepted (conditions)Belastingdienst
Australia5 yearsFrom date of filing returnAcceptedATO
New Zealand7 yearsFrom end of tax yearAcceptedInland Revenue NZ
Singapore5 yearsFrom relevant year of assessmentAcceptedIRAS
Japan7 years (corporations) / 5 years (individuals)From end of fiscal yearAcceptedNational Tax Agency
India8 yearsFrom date of annual return filingMixedIncome Tax Department
South Africa5-7 years (5 for VAT, 7 for income tax)From date of submissionAcceptedSARS
Brazil5 yearsFrom date of tax payment or filingMixedReceita Federal

Note that France and Italy each impose dual retention periods depending on whether the obligation arises from civil/commercial law or tax law. In France, fiscal records must be kept for 10 years while commercial obligations require 6 years. In Italy, the civil code mandates 10 years while tax records require 5. When in doubt, defaulting to the longer period is the safer approach.

The "Clock Starts" column above is a deliberate simplification. The actual trigger date for the retention clock varies by jurisdiction and situation, and getting it wrong can mean disposing of records too early.


When the Retention Clock Starts

A "7-year retention period" does not mean seven years from the invoice date. The actual end-date of your retention obligation depends entirely on when the clock begins counting, and that varies by jurisdiction. Two countries with identical headline retention periods can produce end-dates that differ by more than a year. Getting this wrong means either destroying records too early and facing penalties, or hoarding documents long past their required retention window.

Three distinct clock-start models govern the majority of jurisdictions.

From the End of the Tax or Fiscal Year

This is the most common model globally. The retention period does not begin on the date an invoice is issued or paid. Instead, it begins on the first day after the close of the tax year in which the transaction falls.

Countries using this approach include:

  • United Kingdom - 6 years from the end of the relevant accounting period. Businesses meeting UK VAT invoice compliance requirements under HMRC rules should note that VAT records follow a separate 6-year window from the end of the prescribed accounting period, not the invoice date.
  • Germany - 10 years from the end of the calendar year in which the invoice was issued.
  • Canada - 6 years from the end of the tax year to which the records relate.
  • New Zealand - 7 years from the end of the relevant tax year.
  • Japan - 7 years from the end of the fiscal year containing the transaction.
  • Netherlands - 7 years from the end of the fiscal year.
  • France - 10 years from the end of the fiscal year.

Under this model, an invoice issued on the first day of your fiscal year carries the longest effective retention period, since the entire remaining year must elapse before the clock even starts.

From the Filing Date or Date of Return

Under this model, the clock begins when the tax return covering the relevant period is filed or due, whichever is later. This creates a variable start date tied to your actual filing behavior.

  • United States - The IRS requires retention for 3 to 7 years from the date the return is filed or the due date, whichever is later. The standard period is 3 years, extending to 6 or 7 years in cases involving underreported income or fraud.
  • Australia - 5 years from the date of filing the relevant return.
  • India - 8 years from the date of filing the annual return.

The filing-date model means that late filing directly extends your retention obligation. A return filed two months late pushes every associated invoice's destruction date out by two months.

From the Payment or Transaction Date

A smaller number of jurisdictions tie the clock to the date of the underlying transaction or tax payment rather than to fiscal year boundaries or filing dates.

  • Brazil - 5 years from the date of tax payment or filing.
  • Singapore - 5 years from the relevant year of assessment.

A Concrete Example

Consider an invoice dated January 15, 2025.

For a UK business with a March 31 fiscal year-end, the 6-year retention clock starts on April 1, 2025 (the day after the accounting period closes). That invoice must be retained until March 31, 2031 - a total of 6 years and approximately 2.5 months from the invoice date.

For a US business that files its 2025 tax return on the April 15, 2026 deadline, the standard 3-year clock starts on April 15, 2026. That same invoice can be destroyed after April 15, 2029 - roughly 4 years and 3 months from the invoice date, despite the headline period being only 3 years.

The practical takeaway: actual financial document retention periods are almost always longer than the headline number. The gap between the invoice date and the clock-start date adds months or even over a year to the real-world retention obligation. Any compliant retention policy must calculate destruction dates from the correct clock-start trigger, not from the invoice date.

These clock-start calculations assume standard circumstances with no complicating factors. When invoices are stored electronically rather than on paper, jurisdiction-specific rules for digital retention add another layer of requirements.


Electronic Invoice Storage and Digital Retention Rules

Most major jurisdictions now accept electronic-only invoice storage, but the technical and legal requirements behind that acceptance vary significantly. Some countries require digital invoices to meet specific format standards or pass through government platforms. Others require only that the original data remains intact, readable, and accessible on request. Understanding where each jurisdiction falls on this spectrum determines whether your organization can go fully paperless and what conditions you must satisfy to do so.

Fully Digital Accepted with Minimal Conditions

Several countries permit electronic invoice storage with straightforward requirements centered on data integrity and accessibility:

  • United States - Revenue Procedure 98-25 governs the IRS requirements for electronic storage systems: completeness, accuracy, accessibility, readability, and machine-sensibility. Records must be available for IRS inspection in their original electronic format, and the system must include an indexing mechanism that allows efficient retrieval.
  • Canada - Information Circular IC05-1 sets out the CRA's guidelines for electronic record retention. Records must be kept in an electronically readable format, remain accessible throughout the retention period, and be producible for audit upon request.
  • United Kingdom - HMRC accepts digital records as long as they are legible, accurate, and can be produced on demand. Making Tax Digital (MTD) requirements have further pushed businesses toward digital-first record keeping.
  • Australia - The ATO requires that digital copies be a true and clear reproduction of the original, stored in a way that prevents alteration.
  • Singapore and New Zealand - Both jurisdictions accept electronic storage with the same core requirements: records must remain in a readable format and be accessible for the full retention period.

For these jurisdictions, a standard document management system with proper backup and access controls will typically satisfy compliance obligations.

Fully Digital Accepted with Specific Technical Requirements

Other countries accept or mandate electronic invoicing but impose stricter format, platform, or archival requirements:

  • Germany - Electronic invoicing for business-to-government (B2G) transactions must use the XRechnung or ZUGFeRD format. Beyond the invoice format itself, Germany's e-invoicing requirements extend to archival practices: the Bundeszentralamt fur Steuern requires that electronic archives ensure immutability of stored records under the GoBD (Principles for Properly Maintaining and Storing Books, Records, and Documents in Electronic Form). Any changes to archived invoices must be logged with a full audit trail.
  • France - Beginning in 2026, France's 2026 e-invoicing mandate requires businesses to issue and receive invoices through the government's Portail Public de Facturation (PPF) or certified Partner Dematerialization Platforms (PDPs). This is a phased rollout that will eventually cover all B2B transactions.
  • Italy - Electronic invoicing is not optional. All invoices must be issued in the FatturaPA XML format and transmitted through the Sistema di Interscambio (SDI), the government's centralized exchange platform. Paper invoices are not valid substitutes for domestic B2B and B2C transactions.
  • Netherlands - The Dutch tax authority accepts electronic invoices and encourages Peppol-based e-invoicing, particularly for government contracts. Stored invoices must maintain authenticity of origin and integrity of content.

Mixed or Transitional Requirements

A few jurisdictions have adopted mandatory electronic invoicing but retain certain paper-based obligations:

  • Brazil - The Nota Fiscal Eletronica (NF-e) is mandatory for most commercial transactions, and the XML file issued through the government's SEFAZ system is the authoritative record. However, some states still require a printed DANFE (auxiliary document) to accompany goods in transit, creating a hybrid paper-digital requirement.
  • India - GST e-invoicing is mandatory for businesses exceeding specified turnover thresholds (currently applicable to businesses with aggregate turnover above INR 5 crore). Below that threshold, paper invoicing remains acceptable. Businesses subject to the mandate must generate an Invoice Reference Number (IRN) through the government's Invoice Registration Portal.

Practical Takeaway

For multinational organizations, the most efficient approach is to adopt an electronic storage system that meets the strictest requirements you face across your operating jurisdictions. Germany's immutability and audit-trail standards and Italy's mandatory format and government-platform transmission represent the high end of compliance demands. A system that satisfies these requirements will automatically meet the less demanding standards of jurisdictions like the US, Canada, or Australia.

Even with the correct retention clock and compliant storage format in place, certain circumstances can push the required retention period well beyond the standard numbers.


What Extends the Standard Retention Period

The retention periods listed in the comparison table above are minimums, not absolutes. Several common circumstances require businesses to keep invoices well beyond those standard windows, sometimes indefinitely. Understanding these extension triggers is critical for any retention policy that aims to be genuinely compliant rather than just superficially complete.

Active Audits and Investigations

In most jurisdictions, if a tax authority opens an audit or investigation before the standard retention period expires, all relevant records must be retained until the matter is fully resolved. This applies even if the resolution takes years beyond the original retention deadline. You cannot destroy records simply because the calendar says the standard period has passed if there is an open inquiry.

The United States warrants particular attention here. While the standard IRS audit window is three years from filing, the IRS has no statute of limitations whatsoever for fraudulent returns. If the IRS determines that a return was fraudulent, it can investigate records from any prior year, regardless of how long ago the return was filed. This means invoices supporting a return later deemed fraudulent must, in theory, be available indefinitely.

Ongoing Disputes and Litigation

If an invoice or the underlying transaction it documents is part of an active legal dispute, the obligation to retain that invoice supersedes the standard retention period. This principle applies universally across jurisdictions. Whether the dispute involves a breach of contract claim, a supplier disagreement, or a tax appeal, the records must remain intact and accessible until the dispute is fully settled, all appeals are exhausted, and any resulting judgments are satisfied.

Destroying records that are subject to litigation can result in adverse inference rulings, where a court assumes the destroyed documents contained evidence unfavorable to the party that destroyed them. The consequences extend far beyond retention penalties.

Capital Assets and Depreciation

Invoices tied to capital assets such as property, equipment, and vehicles follow a different retention clock entirely. Rather than counting from the original transaction date, the retention period typically begins after the asset is fully depreciated or disposed of. This can extend the effective retention requirement by decades.

Consider a practical example from Australia, where the standard retention period is five years. If your business purchases manufacturing equipment in 2020 and disposes of that equipment in 2035, the purchase invoice must be retained until 2040, which is five years after disposal. That amounts to 20 years from the original transaction date, far exceeding the standard five-year requirement that the comparison table shows.

Similar rules apply across most jurisdictions. Any invoice related to the acquisition, improvement, or maintenance of a capital asset should be flagged for extended retention from the moment it is recorded.

Fraud, Substantial Underreporting, and Omissions

Beyond active fraud investigations, many jurisdictions impose extended retention requirements when returns contain substantial errors, even without deliberate fraud. In the United States, the statute of limitations extends from three years to six years if gross income is understated by more than 25%. If a return is fraudulent or was never filed at all, there is no limitation period.

Most other jurisdictions follow a similar pattern. Standard retention periods assume good-faith compliance. When fraud, gross negligence, or significant omissions are involved, those standard periods expand substantially or disappear entirely. The practical implication is that if there is any question about the accuracy of a historical return, the supporting invoices should not be destroyed.

The Practical Rule

When there is any doubt about whether an extension trigger applies, retain longer. Storing 10,000 invoices digitally for an extra three years costs under $50 in cloud storage. A single disallowed deduction from missing records can cost tens of thousands, and a fraud penalty at 75% of the underpayment can reach into six figures.

These retention extensions become especially complex when a business operates across multiple jurisdictions, each with its own rules for audits, disputes, and asset depreciation.


Cross-Border Invoice Retention for Multinationals

A single invoice can trigger retention obligations in more than one country. When a German supplier invoices a US buyer, both German and US tax authorities may have jurisdiction over that transaction. The business on each side must satisfy its own country's requirements, and in many cases, the same entity faces overlapping obligations from multiple jurisdictions simultaneously.

The guiding principle is straightforward: retain for the longest applicable period. If an invoice falls under both German rules (10 years) and US federal rules (3-7 years), keep it for 10 years. Applying the longest period across all relevant jurisdictions is the safest and most practical default.

Three Scenarios Multinationals Face

1. Headquartered in one country, operating in others. The headquarters' home-country retention rules govern its own records, but each local subsidiary or branch must comply with the retention requirements of the country where it operates. A US-headquartered company with a French subsidiary cannot apply US retention periods to invoices generated and received by the French entity. Those invoices fall under French rules (10 years for commercial records), regardless of what the parent company's policy says.

2. VAT/GST registered in multiple countries. Each VAT or GST registration creates a distinct retention obligation in that jurisdiction. A business holding both a UK VAT registration and a German VAT registration must retain UK VAT invoices for 6 years under HMRC rules and German VAT invoices for 10 years under AO requirements. These are separate obligations that run independently, each with its own retention clock and its own rules on storage format and accessibility.

3. Transfer pricing and intercompany transactions. Intercompany invoices attract heightened scrutiny from tax authorities because they directly affect how profits are allocated across jurisdictions. These records may need to be retained for the longest period applicable to any entity involved in the transaction. Several countries also impose additional transfer pricing documentation requirements that extend beyond standard invoice retention periods, sometimes requiring supporting records to be available for 10 years or more regardless of the base retention rule.

The Practical Approach

Rather than tracking different destruction dates for invoices from each jurisdiction, many multinationals adopt a single global retention period based on the longest requirement across all countries where they operate. For most companies with European operations, this means defaulting to a 10-year retention period for all invoices, regardless of origin.

This approach is easier to administer, eliminates the risk of prematurely destroying records that are still required in another jurisdiction, and removes the need for staff to classify every invoice by applicable country before filing. The marginal cost of storing invoices for a few extra years is almost always lower than the cost of a compliance failure in a single jurisdiction.

A Worked Example

Consider a US-headquartered company with a German subsidiary and a UK VAT registration. This entity has three distinct retention obligations:

  • US invoices (headquarters): Retain for 3-7 years from the filing date of the relevant tax return under IRS rules.
  • German invoices (subsidiary): Retain for 10 years from the end of the calendar year under German tax law. Electronic archives must meet GoBD immutability standards.
  • UK VAT invoices (VAT registration): Retain for 6 years from the end of the relevant accounting period under HMRC rules.

For an intercompany invoice between the US headquarters and the German subsidiary, both US and German retention obligations apply simultaneously. The practical answer: retain that invoice for 10 years under German rules, which automatically satisfies the shorter US requirement.

Applying a single 10-year retention period across all three jurisdictions eliminates the need to track three different destruction schedules and three different clock-start rules for every invoice.

Despite this clear and conservative principle, many organizations still make avoidable mistakes in international invoice record keeping.


Common Mistakes and Penalties for Non-Compliance

Even finance teams with good intentions run into retention failures. The rules vary enough across jurisdictions that assumptions made in one country create real compliance gaps in another. Here are the five most frequent invoice retention mistakes businesses make, followed by the specific penalties they risk.

Five Retention Mistakes That Create the Most Exposure

1. Applying one country's rules globally

This is the single most dangerous mistake for multinationals. A US-headquartered company that applies the standard 3-year IRS retention period to its German subsidiary's invoices will destroy records seven years too early. Germany requires 10 years. France requires 10. The assumption that "our home country rules are good enough" creates systematic non-compliance in every jurisdiction with a longer retention period, and most jurisdictions do have longer periods than the United States.

2. Starting the retention clock from the invoice date

As covered earlier in this guide, most countries do not start the retention clock on the date printed on the invoice. The trigger is typically the end of the fiscal year in which the transaction occurred, the tax return filing date, or the end of the VAT reporting period. Starting the clock from the invoice date can mean destroying records months or even years before the actual retention period expires. A December invoice in a calendar-year company, for example, might appear to expire a full year earlier than it actually does when the clock runs from the fiscal year-end.

3. Ignoring capital asset invoice extensions

Routine expense invoices and capital asset invoices have fundamentally different retention timelines, but many organizations apply the same destruction schedule to both. Invoices for equipment, vehicles, property, and other capital assets must typically be retained for the standard period after the asset is disposed of, not after the invoice is issued. A piece of equipment purchased in 2020 and sold in 2035 means that purchase invoice needs to be kept until 2038 or later, depending on the jurisdiction. Applying the standard 7-year or 10-year rule from the purchase date would destroy the record decades too early.

4. Destroying records during an active audit or investigation

Standard retention periods become irrelevant the moment a tax authority opens an audit, launches an investigation, or initiates a dispute. Even if the normal retention period has technically expired, any records connected to an open matter must be retained until that matter is fully resolved. This includes records that might seem tangentially related. Destroying invoices during an active audit, even unintentionally through an automated destruction schedule, can escalate a routine examination into an obstruction charge.

5. Failing to meet electronic storage technical requirements

Having digital copies of invoices is not the same as having legally valid digital records. Germany's GoBD requirements demand immutability and audit trail logging. Several EU countries require qualified electronic signatures or specific archival formats. Italy mandates transmission through the Sistema di Interscambio. If stored invoices do not meet the jurisdiction's technical requirements, the records may be treated as legally nonexistent, even though the files are physically sitting on a server. The business has the records but cannot use them as evidence.

Penalties by Jurisdiction

The financial consequences of retention failures range from administrative fines to criminal prosecution, depending on the jurisdiction and the severity of the violation.

United States: The IRS can disallow deductions entirely if supporting invoices are unavailable, and it has the authority to estimate taxable income when records are missing. Accuracy-related penalties run at 20% of the tax underpayment. If the IRS determines fraud, that penalty jumps to 75% of the underpayment. Willful destruction of records during a federal investigation carries criminal penalties, including fines and imprisonment.

Germany: Bookkeeping violations under the GoBD and Abgabenordnung can result in fines of up to EUR 25,000. More consequentially, if the Finanzamt determines that records are missing or incomplete, it can reject the company's reported figures and estimate taxable income at its own discretion, which almost always results in a higher tax assessment than the actual figures would have produced.

United Kingdom: HMRC can impose a fixed penalty of GBP 3,000 for failure to maintain adequate records. Beyond that fixed amount, if inadequate records lead to an inaccurate tax return, HMRC can charge penalties of up to 100% of the tax due, scaled based on whether the failure was careless or deliberate.

Australia: The ATO applies a tiered penalty structure based on culpability. A failure due to lack of reasonable care results in a penalty of 25% of the tax shortfall. Recklessness increases that to 50%. Intentional disregard of record-keeping obligations carries a penalty of 75% of the shortfall. The ATO also has the authority to deny deductions where supporting documentation cannot be produced.

Across all jurisdictions, the pattern is consistent: missing records shift the burden of proof to the taxpayer, and tax authorities will use their estimation powers in ways that rarely favor the business.

Understanding these requirements and the penalties for falling short provides the foundation. The next section covers how to translate this knowledge into a practical, enforceable invoice retention policy.


Building a Compliant Invoice Retention Policy

Knowing the retention periods is only half the challenge. Translating that knowledge into a working policy that your organization can actually follow requires deliberate structure. These six steps will help you build or update an invoice retention policy that holds up across every jurisdiction where you operate.

1. Map your jurisdictions. Start by listing every country where your business has a legal entity, tax registration, or permanent establishment. Do not limit this to countries where you have offices. A VAT registration in a country where you have no physical presence still creates a retention obligation in that jurisdiction. Update this list whenever the business expands into new markets or restructures existing entities.

2. Identify the longest applicable period. Using the comparison table earlier in this guide, determine which jurisdiction imposes the longest retention requirement. For most businesses with European operations, this means defaulting to 10 years as the organization-wide minimum. Applying the longest period globally is simpler than managing different destruction schedules per country, and it guarantees compliance everywhere. The trade-off is additional storage cost, which for digital records is typically negligible.

3. Document clock-start rules. For each jurisdiction, record precisely when the retention clock begins. As covered earlier in this guide, some countries count from the invoice date, others from the end of the fiscal year, and others from the date of the last related transaction. Build your destruction eligibility dates from these clock-start rules, not from the invoice date alone. A spreadsheet or retention management system that calculates the earliest permissible destruction date per invoice prevents premature disposal.

4. Adopt electronic storage that meets the strictest standard. Rather than configuring different storage protocols for each country, choose an electronic archiving system that satisfies the most demanding jurisdiction's requirements. In practice, this typically means meeting Germany's GoBD immutability and audit-trail standards. A system that prevents alteration, logs all access, and preserves original formatting will automatically satisfy the less stringent digital storage rules found in most other jurisdictions.

5. Flag capital assets and special circumstances. Create a tagging system that identifies invoices tied to capital assets, ongoing legal disputes, open tax audits, or loss-carryforward claims. These records must be excluded from standard destruction schedules because their retention periods extend well beyond the baseline. Without explicit tagging, these invoices risk being swept up in routine purges, exposing the organization to penalties during future audits or litigation.

6. Review annually. Retention requirements change as governments update tax codes and digital archiving standards. Schedule an annual policy review that accounts for new jurisdictions entered during the year, regulatory updates in existing jurisdictions, and any changes in business operations that alter your retention obligations. Assign a specific owner for this review to prevent it from falling through the cracks.

A well-structured digital archive makes every one of these steps more manageable. Centralized storage with consistent metadata enables efficient retrieval during audits, jurisdictional tagging for country-specific rules, and automated retention tracking that flags records approaching their destruction eligibility dates. For organizations still managing paper invoice archives or building digital retention systems, implementing practical systems for organizing invoices and receipts is the critical first step. Organizations looking to convert paper archives into searchable digital formats can explore automated invoice data extraction tools to facilitate the transition.

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