Compliance Services

Greece is looking to implement a phased roll-out of its upcoming e-invoicing MyData changes, starting on 1^st September 2021. As a reminder, e-invoicing in this context refers to the connection of a certified e-invoicing certified service provider to the MyData platform. Tungsten does not meet the requirements for a certified provider, so we are requesting that suppliers attach their legal invoice to our Tungsten solution as we won’t be able to create the legal artefact for suppliers once the changes take effect.

Here are some key dates to watch out for:

• 1 September 2021: Companies will proceed on a phased basis from this date around the electronic transmission to MyData and the interconnection specifically of cash registers with Greek electronic system. This will be based on the type of their accounting books and annual revenues;
• 1 October 2021: The mandatory transmission of business documents to the MyData platform becomes mandatory;
• From 1 October 2021 onwards, the following businesses must send their accounts receivable documents (i.e. invoices) which they issue:
  • Businesses with double-entry accounting books with a turnover of over € 50.000.
  • Businesses with single-entry accounting books with a turnover of over € 100.000.
• 1 November 2021: all other companies must submit their invoices.

The Greek MyData changes have been delayed multiple times already. So far we have not heard anything to indicate that these changes will not be going ahead on 1 September 2021. We will keep you updated.

Spain’s e-invoicing landscape looks like it may be expanding into the B2B sector, for transactions between companies and the self-employed

The Spanish government recently announced a draft law for ‘Creation and Growth of Companies’. This covers many elements- one being the proposal to extend the obligation to exchange invoices for B2B transactions as well as B2G transactions.

The public consultation for this is open until 6 September 2021.

With the voluntary phase of the mandate fast approaching in January 2022, the Polish Ministry of Finance has published some new documentation.

This includes the draft version of the e-invoicing structure and a sample invoice, which can be found on the Polish Ministry of Finance website: https://www.gov.pl/web/kas/krajowy-system-e-faktur

The voluntary phase of the Polish national e-invoicing mandate has been delayed until January 2022. It was originally scheduled to be implemented in October 2021.

Portugal has previously communicated the admissibility of invoices in PDF format as electronic invoices. Order no. 260/2021-XX11, dated 27^th July 2021, has extended this permissibility until 31 December 2021. This had previously been extended until 30 September 2021.

PDFs must be digitally signed from January 2022.

There has now been some further progress around transactions between Italy and San Marino – the Italian Revenue Agency has published technical specifications via Provision no. 2021/211273. These technical specifications will provide details around how invoices will be issued and received with San Marino residents for goods and services.

Here are some key dates to watch out for:

• 1^st October 2021- the Decree comes into force;
• Until 30^th June 2022- paper invoices can still be issued;
• 1^st July 2022: Mandatory for Italian taxpayers to issue only e-invoices.

In Saudi Arabia, the deadline for the implementation of Phase 2 of the e-invoicing mandate has been delayed to 1^st January 2023 and it will be implemented in waves by targeted taxpayer groups. Select taxpayer groups will be informed 6 months prior to the go-live date.

In relation to Phase 1 – the Generation Phase, which will be enforced by December 4^th, 2021, there is no prescribed invoice format. However, e-invoices must be issued as a structured file. This means that from the implementation date, paper and PDF invoices no longer qualify as valid tax invoices.

The mandate rules for Phase 2 remain unchanged. E-invoices must be issued in XML/Hybrid (PDF A-3) format and suppliers will need to clear the invoices with GAZT before sending these to buyers. Due to the technical nature of the requirements in Phase 2, taxpayers are encouraged to consult a solution provider or their internal technical teams to ensure their e-invoicing systems comply with ZACTA (General Authority for Zakat and Tax) requirements.

In 2020, Vietnam delayed its implementation date of mandatory electronic invoicing until July 1, 2022. So far, we have not heard signals that suggest any further delay.

From July 2022, paper and PDF invoices no longer qualify as valid tax invoices. Under the mandate, the e-invoice must be in XML format, include a digital signature and be securely stored for ten years. In addition, Invoices need to be in Vietnamese language; a second language is allowed. The second language needs to be placed in brackets next to the Vietnamese texts or under the Vietnamese texts using a smaller font.

There will be two types of e-invoices: the e-invoice with tax verification code and e-invoice without tax verification code. The process with the tax verification code is so -called pre-clearance where invoice data must be submitted to the tax office (GDT- General Department of Tax). Upon registration and approval of the invoice data, the tax office returns a specific code that needs to be included in the invoice that is sent to the buyer. The requirement to add a tax verification code to the invoices depends on the taxpayer’s business sector, tax risk, and annual revenue.

To use either type of e-invoice in Vietnam, companies must register and receive approval from the Vietnamese tax authorities via the website of the General Taxation Department.

The Australian government has announced to mandate e-invoicing for all levels of government by 1^st July 2022 as part of the Digital Business Plan. Australia operates its e-invoicing system based on the PEPPOL framework. To send or receive an e-invoice, a business must connect to the PEPPOL Network through an Access Point. Australia’s Tax Office manages a registry of Access Point servers that have been officially accredited by the tax office.

The Hungarian government has postponed its e-VAT return concept to October 2021. This was initially due to be implemented in July 2021. The e-VAT return concept involved the tax authority preparing a draft VAT return for taxpayers based on real-time reporting data collected.