Key legal question
Whether false invoices prepared at the request of the recipient can constitute forgery as bookkeeping documents under Art. 251 StGB.
Extracted holding
Yes. If an invoice is objectively and subjectively intended as a bookkeeping voucher and is created in collusion with the accounting entity, it is a document and can satisfy forgery.
Extracted reasoning
A false invoice is usually not a document, but it becomes one when its purpose is to serve as a bookkeeping voucher. That purpose can arise from cooperation with the accounting company and exists already upon drafting, not only upon booking.