Impact of Greek Tax Reform on E-Invoicing

Joanna Hysi
August 27, 2020

With the 1 October go-live date for myDATA, the first Greek implementation of Continuous Transaction Controls (CTC), fast approaching, legal clarity around the broader tax reform should ideally be close to completion. Greece’s tax reform is expected to not only cover CTC reporting but also e-invoicing.  So far, however, we have only seen fragmented documentation with no clear mandate defined or communicated for e-invoicing. This creates uncertainty with just a few months before the myDATA roll-out.

Connected but independent frameworks

The fragmented e-invoicing documentation was released at the same time as the myDATA documentation. This created the notion that the two legal frameworks were interconnected in a way that the e-invoicing documentation would only apply to the myDATA implementation.  Part of documentation covered e-invoicing through accredited service providers, introduced in February in Decision No 1035/2020, which, according to myDATA legislation is also one of the data transmission methods to the myDATA platform.  Other methods include reporting from the ERP or online cash registers. However, as further e-invoicing legislation has been published, i.e. e-invoicing incentives for taxpayers choosing to use accredited service providers for their e-invoicing processes, it‘s clear that the two frameworks are – or rather were intended to be – independent.

No immediate change to e-invoicing

It’s important to remember that although the IAPR clearly plans to embrace CTC e-invoicing in the future, for the time being the existing post audit e-invoicing rules remain the same. The myDATA scheme, rolling out on 1 October, doesn’t impact e-invoicing in Greece. Taxpayers can continue issuing paper invoices or electronically, meet the integrity and authenticity requirements by any methods accepted in the VAT Directive (digital signatures, business controls establishing an audit trail between an invoice and supply (BCAT) or EDI with an interchange agreement based on the European Commission 1994 Recommendation), outsource and automate their B2B e-invoicing processes through their chosen service provider, as long as they report their data to the myDATA platform through their ERP.

Businesses that have already automated their e-invoicing businesses processes in Greece, e.g. procure to pay, order to cash, do not need to stop even if their vendor is not accredited. Similarly, vendors that offer automated e-invoicing processes in Greece, can keep doing so without having to become accredited.

A key takeaway for businesses and service providers who operate in Greece is that post audit e-invoicing is still possible and compliance with local post audit legislation is required. However, since the IAPR has already taken steps towards embracing some type of CTC e-invoicing, businesses should expect that further information is expected in the coming months providing welcome clarity on the shape and form of such a clearance system.

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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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