After a period of solid work around the myDATA framework, with little documentation left to implement the entire scheme in Greece, the IAPR has shifted its attention to e-invoicing. Last week the IAPR and the Ministry of Finance signed the long-awaited bill, which once turned into law will enforce the myDATA system within Greece. According to the IAPR’s announcement, the bill will specify: the scope of application, any exceptions, the data to be submitted, the time, methods of transmission and the specific obligations of businesses. In parallel, the bill adds emphasis to continuous transaction controls (CTCs) e-invoicing according to the rules of the new framework, i.e. e-invoicing facilitated through accredited service providers. The bill is expected to be published in the Official Government Gazette in the coming days.
The upcoming bill aims to regulate, not only the myDATA reporting framework, but also to some extent the CTC e-invoicing system. It’s expected that CTC e-invoicing will start on a voluntary basis in July 2020 and that businesses will be given incentives to use the new e-invoicing method.
A committee has been tasked with certifying e-invoicing service providers in line with an accreditation scheme published earlier this year. Service providers have been invited to submit their applications for a “suitability permit” to certify that their e-invoicing solution complies with the IAPR’s requirements for e-invoice issuance, integrity and authenticity and reporting to the myDATA framework.
The certification requirements, as laid down in the accreditation law and the implementing documentation (available on IAPR’s dedicated e-invoicing webpage in Greek), include a set of financial, technical and security criteria as well as requirements for integration capabilities with the myDATA platform.
Uncertainty remains about the criteria against which service providers must be assessed to become accredited. Depending on the degree to which such service providers are expected to handle CTCs on the tax administration’s behalf, criteria may include local establishment and other features that could require non-Greek solution vendors to interconnect with accredited Greek vendors.
The recent announcement states that the required data must be reported in a phased timeline where the key reporting dates are:
- From 20 July 2020, taxpayers can report the required data, if they opt for the reporting method through CTC e-invoicing which is facilitated through service providers.
- From 1 October 2020, taxpayers must report the required data, if they opt for the ERP-reporting method.
- From 1 October 2020, taxpayers must report the required classification data for purchase invoices (inbound) issued from that date onwards.
- From 1 October 2020, taxpayers report the required data from retail transactions. For transactions using cash registers, until a further decision is published by the authorities, aggregate reporting per month is provided for; unless there is an obligation for direct (online) connection with the IAPR, in which case the reporting is done per retail item. For transactions not using cash registers, the reporting per retail item is provided for from 1 January 2021.
- By 31 December 2020, taxpayers must report the required data from sales invoices (outbound) issued from 1 January 2020 until 1 October 2020.
- By 28 February 2021, taxpayers must report the required classification data from purchase invoices (inbound) issued from 1 January 2020 until 30 September 2020.
A changing emphasis
While the myDATA framework takes shape through the upcoming bill, the regulation of CTC e-invoicing in the same bill, signals an interesting policy shift in the IAPR’s VAT reform strategy.
As well as anticipated economic benefits from business automation, the IAPR’s shift to e-invoicing will have a more immediate impact on identifying opportunities to collect VAT alongside authentic, transactional updates to myDATA. Although the IAPR has yet to finalise the format or scheme it will adopt for this purpose, there is a change in emphasis with e-invoicing being facilitated through accredited service providers now appearing to be a higher priority than ERP-based reporting via the myDATA framework.
Sovos has more than a decade of experience keeping clients up to date with e-invoicing mandates all over the world.