The relevant requirements for "daily meal allowances" (digital meal vouchers) are set out in the BMF letter dated 18.01.2019, BStBl I 2019, 66 in conjunction with R 8.1 para. 7 no. 4 LStR. The BMF circular requires, among other things, that employees' meals can only be recognized as wages at the applicable official non-cash benefit value if it is ensured that:
a) a meal (breakfast, lunch or dinner) is actually purchased by the employee every working day. Food is only to be recognized as a meal
if they are suitable for immediate consumption or are intended for consumption during meal breaks,
b) only one allowance per working day (...) can be claimed for each meal,
c) the allowance does not exceed the official non-cash benefit value of the meal by more than € 3.10,
d) the allowance does not exceed the actual price of the meal (...)
It also states "The employer must provide evidence of the above requirements."
These requirements must be proven individually for each digital meal voucher granted. This is only possible with an individual receipt comparison, as offered by Hrmony. It is up to the employer to decide how to fulfill this obligation to provide evidence. The BMF letter presents two possible options:
Variant 1:
"Either to manually check the itemized receipts submitted to him [the employer] by the employee or"
Variant 2:
"to make use of appropriate electronic procedures"
Hrmony has developed such an electronic procedure with the individual receipt comparison.
Sources:
BMF-Schreiben vom 18.01.2019, BStBl I 2019, 66