The General Communiqué no. 509 (communiqué) established the date of transition to the e-delivery note application and the full scope of the mandate. Whilst the communiqué addressed the general use of the application and the basic practices, it didn’t contain all the information businesses require and although the FAQ and information from the Turkish Revenue Administration (TRA) were useful, a guide was necessary.
In February 2020, the TRA released the e-Delivery Application Guideline (guideline) detailing the basic principles. It also answered the questions that companies and integrators had been asking.
Whilst the guideline provided much needed clarity, there are still some confusing scenarios as the deadline of July 2020 approaches.
Among these scenarios is the structure of delivery notes for goods that are not subject to sale and the chain delivery issue.
E-delivery notes issued for goods not subject to sale
One critical concern is that the TRA has included the scenario of delivery notes issued for goods not subject to sale and stated that e-delivery notes must also be issued for these transactions. However, these delivery notes should include additional details in the note section.
To illustrate, let’s say there are goods, equipment, to be shipped for repair/maintenance purposes. An e-delivery note must be issued for these goods with an explanation stated on the document, such as “to be repaired”, “to be painted”, “to change parts” etc.
Similarly, in outsourcing, a sample and consignment processes e-delivery note must be issued.
The chain delivery scenario
Another scenario in the guideline is chain delivery which was illustrated as follows.
Wholesaler “Y” who receives goods from manufacturer “X” may sell the goods directly to the dealer “Z” without actually receiving them. And dealer “Z” may sell the goods that are not yet delivered directly to customer “T”. In this scenario, the goods that are still in the warehouse of manufacturer “X” may be shipped directly to customer “T” by manufacturer “X”.
The schematron file answers the question, “To whom will the e-delivery note be issued in this scenario?” E-delivery notes should be sent directly to the recipient of the goods. So based on our example, the e-delivery note must include the information of customer “T”.
There are control options regarding this issue in the schematron. So, to understand whether the e-delivery note will be sent to a virtual or actual taxpayer, the tax ID/ID number of customer “T” should be checked.
Sovos has more than a decade of experience keeping clients up to date with e-invoicing mandates all over the world.