India – New E-Invoicing Deadlines Announced

Selin Adler Ring
October 15, 2020

After a roller-coaster period, full of changes and updates, India’s e-invoicing reform went live on 1 October this year. This e-invoicing reform is considered to be the second biggest tax development in the country after the introduction of Goods and Services Tax (GTS) in 2017. The Indian authorities chose to go ahead with implementing the e-invoicing reform without any further delay despite many private sector requests asking for more time to prepare. However, this situation resulted in last minute changes for taxpayers.

Early signs of success

The first weeks of the mandate seem to be more successfully executed than the pre-mandate process. This is due to the back-end clearance system of the Invoice Registration Portal (IRP) functioning quite well. According to local news, the e-invoicing uptake has been a success and so far 6.95 million invoices have been cleared through the IRP within the first week of the mandate.

Scope of mandate widened

These early signs of success have given the authorities confidence to announce new deadlines for taxpayers who are currently not in scope of the mandate. The Indian Finance Secretary announced last Friday (9 October) that businesses with a threshold limit of 100 Cr. rupees or more will have access to the IRP from 1 January 2021. And by 1 April 2021, all taxpayers will have access. Furthermore, the e-invoicing mechanism will soon replace the existing e-way bill system according to the Secretary.

Even though these statements seem realistic and in line with the ambitious approach demonstrated by Indian officials so far, there is to-date no official legal action taken by the government to turn the announced dates into legally binding requirements. However, if past actions tell us anything, it’s that it’s just a matter of time.

It’s also unclear from the Secretary’s statement whether it will be mandatory for the indicated taxpayer groups to send their invoices to the IRP by the given dates or merely a possibility. The following days and weeks will shed light on these topics that continue to keep taxpayers on their toes.

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Author

Selin Adler Ring

Selin is Regulatory Counsel at Sovos. Based in Stockholm and originally from Turkey, Selin’s background is in corporate and commercial law, and currently specializes in global e-invoicing compliance. Selin earned a Law degree in her home country and has a master’s degree in Law and Economics.
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