Why you'd want this at all
An XRechnung is raw XML. Useless to the eye, unsatisfying for mental filing. The wish to make it a normal PDF is entirely understandable — and for daily work also sensible.
There is nothing against a readable PDF view. The problem only begins where the view displaces the original.
Allowed: the readable view
You may generate a PDF rendering from an XRechnung, file it, print it, share it in the team. No one forbids that. For approval, visual checking and quick reference it is even recommendable.
This view is a convenience tool. As such it is welcome — the emphasis is on “as such”.
Not enough: the PDF as the sole document
The decisive point: the document subject to retention is the XML, not the PDF generated from it. Any number of differently looking PDFs can be generated from one XML — none of them is bindingly “the invoice”.
Whoever keeps only the PDF and discards the XML has turned machine-evaluable data into a picture. Exactly that the GoBD forbid. The original must remain structured and evaluable.
The right handling
Both instead of either-or:
- Keep the XML original unchanged and audit-proof.
- Additionally generate a readable PDF view — for daily work.
- Treat the view clearly as a view, not as a substitute.
- When converting, never “replace” or delete the original.
Why this matters in a tax audit
In a tax audit the structured original is specifically requested. “We have it as a PDF” is then the wrong answer — even if the PDF is correct in content.
Machine evaluability is not an end in itself: it lets the auditor read data automatically. A PDF cannot do that. Hence the simple maxim: PDF gladly in addition, XML always as the original.