October 2022: E-Invoicing & VAT compliance updates


Welcome to the October 2022 edition of our regular e-Invoicing newsletter.

Please refer to our “Hot topics section for items which may require imminent consideration on your part – this month some updates from the French tax authorities about their mandate for 2024 – while there is still a fair bit of time it remains a very hot topic for our clients. In addition there are some updates to the technical documentation from Italy regarding the changes to their Esterometro process for cross-border sales which we’ve discussed in previous newsletters. Smaller companies operating in India should also note the extension of the scope of their e-Invoicing mandate since it may affect them.

In “Compliance news and updates” we have an update on the legal framework for Spain’s B2B mandate, along with proposed updates to New Zealand’s GST invoicing and record-keeping requirements.

In “Other news”, you can hear about the OECD’s report on tax and e-Invoicing and updates on the EU “VAT in the digital age” initiative.

Hot topics

France Updates to legal framework, FAQs and list of data fields

As we move ever closer to the 2024 French mandate, further legal and technical updates have been forthcoming.

Decree No. 2022-1299 and the October 7 2022 Order relating to the the generalization of electronic invoicing were published, confirming the timeline of the roll-out and adding further detail around the obligations for PDPs (accredited service providers), the outline for the centralized directory, and more information about the e-Reporting framework.

The technical specifications have also been updated to clarify some new data fields which are required to be included on electronic invoices. The list can be found on page 16 of the current technical specifications (in French) which are available on the tax authority website.

In addition there have been amendments within the e-Invoicing / e-Reporting FAQs which may better help businesses understand the requirements. The latest FAQ for French electronic invoicing can be found here (also in French).

For more information about these changes and any clarification you might require about the obligations in France for 2024, please reach out to your OpenText sales team and arrange a consultation with our French tax and e-Invoicing SMEs.

Italy New version of the Compilation Guide for e-Invoicing and the Esterometro

There have been a number of version updates to the technical documentation which now describes various of the Italian document types in more detail, while also adding a new document type.

Specifically covered in the updates are document types TD17 (cross-border self-billing), TD18 (intra UE goods purchases), and TD19 (relating to purchases from the Republic of San Marino).

In addition the new document type TD28 will communicate data related to paper invoices for purchases from San Marino.

Customers who have these uses cases should read the new version 1.8 Esterometro documentation.

All of the current technical specifications can be found here on the Italian tax agencies website.

Customers with these use cases should discuss with their service provider any changes that may need to be made to the data you provide in your invoices and if any changes may be required to your current implementation of data translation maps.

India – e-Invoicing mandate to be extended to smaller companies on 1st January 2023

India continues to extend the reach of their e-Invoicing mandate, announcing a reduction in the revenue threshold whereby companies will be required to comply.

As of January 1st 2023 the smaller companies, that have an annual revenue above to INR 5 crores (50m Indian Rupees, equivalent to around 600k USD / €617k EUR) will be required to comply with the e-Invoicing mandate.

This is part of an ongoing plan with an ultimate goal to lower the threshold to all companies with a revenue of INR 1 crore and higher (10m Indian Rupees / $120k USD / €122k EUR).

Compliance news and updates

Spain – legal framework for e-Invoicing published, still lacking technical specifications

The new decree for the creation and growth of companies (Crea y Crece Law) finished going through parliamentary process and was published in the Spanish Gazette (Boletin Oficial del Estado) to cover the previously announced mandatory B2B e-Invoicing regime planned for July 2024.

The mandate will be targeted initially at taxpayers with an annual turnover above 8m Euro, and all remaining taxpayers will be obliged to invoice electronically two years later.

While we know some high level details about the requirements there is still no sign of the full technical specifications, although businesses can in principle already begin to adopt B2B e-Invoicing voluntarily using FACeB2B in order to start preparing for the upcoming mandatory phase.

New Zealand modernization of GST invoicing / record-keeping from 1 April 2023

The tax authorities in New Zealand announced updates to their GST invoicing and record keeping obligations which will affect the archiving of tax invoices, credit notes and debit notes.

The proposed changes will be dependent on the value and type of supply, details of which are still to be confirmed, and will allow the use of both “Business Controls” (transaction records, accounting systems, contracts etc) and the use of automated exchanges such as PEPPOL which is already being rolled out as part of the Business to Government e-Invoicing process.

Other news

OECD – Report published on e-Invoicing / e-Reporting and continuous controls

The OECD have been examining the increasing use of continuous transaction control based systems for VAT reporting in order to see how these fitted with the concepts they had outlined in their previously published “TAX Administration 3.0: The Digital Transformation of Tax Administration“.

A new report has been published which is a summary of discussions between officials from China, Canada, Chile, Hungary and Spain and based on responses from 71 tax administrations about their own current situation and plans.

The report, entitled “Tax Administration 3.0 and Electronic Invoicing – Initial Findings” can be found at the link provided.

EU “VAT in the digital age– Detailed reports now available

In our newsletter of February this year we discussed an European Union initiative referred to as “Vat in the digital age”. The main documentation is available here.

The European Commission has now published more detailed related reports:

These reports can be downloaded from the links provided above.

Disclaimer: This newsletter is intended to reflect the direction the industry is moving and does not a reflect a commitment for the OpenText Active Invoices with Compliance (AIC) product development roadmap to meet any particular stated regulations.

Ken Clark

Ken Clark is a Director of Product Marketing for OpenText Business Network based in the UK. For over 30 years Ken has been a subject-matter expert in the areas of digital transformation and automation, B2B/EDI/A2A integration, and e-Invoicing and tax compliance. Ken spent much of his career as a hands-on practitioner, consulting on customer problems and implementing business-focused solutions around global supply chain management, order-to-cash and procure-to-pay. Today Ken focuses on solutions for information exchange, B2B and A2A integration, and e-Invoicing.

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