Companies are generally liable for the correct payment of wage tax. For meal subsidies, this means: If receipts are not properly checked and reimbursed, tax back payments can arise during a tax audit – including interest and possibly fines.
⚠️ Note: The following information is for your information only and does not constitute tax or legal advice. If you have questions, please contact your tax advisor directly.
What Does the Legislator Require?
According to the BMF letter dated 01/18/2019 (BStBl I 2019, 66), the employer is required to individually verify the conditions for each meal voucher granted. The BMF letter provides two permissible methods for this:
“[…] to manually check the individual receipt proofs submitted by the employee or to use corresponding electronic procedures […]”.
This means: Without a systematic receipt check – either manual or electronic – the employer does not fulfill their verification obligation and exposes themselves to tax risk.
What Specific Risks Exist?
| Risk | Details |
|---|---|
| Wage Tax Back Payment | If non-reimbursable items are reimbursed, the tax office can demand the difference |
| Social Security Back Payments | Incorrect handling can also lead to social security contributions being reclaimed |
| Interest | Back payments are generally subject to interest |
| Employer Liability | The employer is personally liable for the correct wage tax payment |
How Does Hrmony Protect Employers?
Hrmony carries out the legally required individual receipt verification as an electronic procedure in accordance with the BMF letter. This means for you:
- ✅ Each receipt is automatically checked for reimbursability
- ✅ Non-reimbursable items (e.g., alcohol, tobacco, non-food) are automatically excluded
- ✅ All receipts are archived for tax audits
- ✅ The employer’s obligation to provide proof to the tax office is fulfilled
- ✅ In the event of a tax audit, Hrmony provides the receipt archive
Important: According to the Terms and Conditions, Hrmony is liable for the correct application of the agreed verification catalog. However, the final tax assessment by the tax authorities is outside Hrmony’s responsibility. Hrmony assumes no liability for any tax reassessments by the responsible tax office.
Additional Sources and Information
- 📄 BMF letter dated 01/18/2019, BStBl I 2019, 66
- 📄 What Does “Individual Receipt Verification” Mean?
- 📄 What Happens in the Event of a Tax Audit?
- 📄 Proof and Verification Obligations with Hrmony Meal Subsidy
Still have questions? Our Operations Team is happy to assist you: 📧 operations@hrmony.de