E-Invoicing Mandate Planned in Second EU Country

Joanna Hysi
May 11, 2018

The floodgates may be opening. Following the EU’s approval of mandatory e-invoicing in Italy, it appears that Greece will be the next European Union member state to follow in its footsteps.

As announced after the meeting of the intergovernmental group on 23 April 2018, the introduction of a nationwide mandatory e-invoicing framework will come into force in Greece by 1 January 2020. With this, the Greek Ministry of Finance and the Public Revenue Authority will mandate the real-time submission of electronic invoices and the electronic maintenance of statutory books. What this suggests is that Greece will implement a clearance model, meaning that data flows will be orchestrated around the needs of three parties: the supplier, the buyer, and the Greek tax administration.

To this end, a working group will be set up with the participation of representatives of the Greek economic and industry sectors. The group’s aim will be to identify the necessary actions and infrastructure required for the implementation of a planned pilot measure, that will be introduced to a significant percentage of enterprises in Greece, as early as 1 January 2019.

In the announcement, Deputy Finance Minister Katerina Papanatsiou referred to the benefits of the widespread use of electronic invoicing and its application in improving the collection of VAT, which are core tenants of the government agenda. The benefit to Greece is undeniable, uncollected VAT revenues in Greece in 2015 were estimated at 5 billion euros, according to a report by the European Commission.

The state of e-invoicing in Greece

To date, Greece has followed the EU wide rules on e-invoicing. The planned e-invoicing mandate breaks with this and means that it would be the second EU country to introduce a clearance model. Italy’s route to mandatory e-invoicing was greenlit just this month when the EU granted the necessary derogation from two provisions in the EU VAT Directive. Greece will likely have to go down a similar route.

But internally Greece also has much work to do. By 28 November 2018 Greece will transpose the Directive 2014/55/EU on electronic invoicing in public procurement thus making the receipt of e-invoices mandatory for public authorities. This is the first step to mandatory e-invoicing in Greece, though still following the EU legislation.

The second stage will be the formalization of the mandatory framework with respect to B2B and B2C e-invoicing. While little is known about exactly what this will constitute further announcements can be expected throughout the year in preparation for the first deadline of January 2019.

What we know about the proposed framework

Through communication from AADE we know that the VAT digitization measures will:

  • Cover the real-time submission of invoices and receipts and electronic maintenance of statutory books.
  • Be implement for 110,000 companies starting on 1 January 2019 – the remainder of companies will need to be compliant from 1 January 2020.
  • Use the governmental platform, TAXIS, and all companies will need to connect to this.

The full process, its technical specifications, the secure data exchange and the responsibilities of the service providers are expected to be defined by a joint decision, made shortly, by the Ministry of Finance and AADE.

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Joanna Hysi

Joanna is a Senior Regulatory Counsel at Sovos. Based in Stockholm and originally from Greece, Joanna’s background is in commercial and corporate law with research focus on EU law and financial innovation. Joanna earned her degree in Law in Greece and her masters in Commercial and Corporate from London School of Economics and Political Science (LSE) in London.
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