Malaysia CTC e-invoice Reporting:

From August 2024, e-invoicing in Malaysia will become mandatory for taxpayers with an annual turnover or revenue of more than RM100 million. The mandate will follow the continuous transaction control (CTC) model and will require e-invoices to be validated by the country’s tax authority, as well as reporting certain transactions. Rollout to all other taxpayers undertaking commercial activities in Malaysia will follow in 2025.

Read on for an overview of Malaysia e-invoicing requirements and bookmark this page to stay updated with the latest mandate developments.  

Table of contents

At a glance: Malaysia e-invoicing

The issuance of an electronic invoice and submission for validation to the IRBM’s Platform (MyInvois) will be mandatory in Malaysia for certain determined transactions (e.g. automotive, aviation, construction).

For transactions where e-invoicing is mandatory, and in all other transactions where the buyer requests the issue of an e-invoice, the supplier will need to issue an e-invoice in XML or JSON format and submit it to the IRBM´s MyInvois platform for validation.

To comply with this e-invoicing requirement, taxpayers can use the MyInvois platform through the free solution offered by IRBM or integrate through specific APIs. A Software Development Kit has been released by the IRBM for this purpose.

The platform will perform certain validation checks, not only to the e-invoice structure but also to Taxpayer Identification Numbers (TIN). Once the e-invoice receives validation from IRBM, buyers are allowed to submit rejection requests stating the rejection reason.

On the other hand, suppliers can agree to such rejections and issue cancellations of the e-invoice during a 72-hour period.  

Following validation, suppliers handle the exchange of validated e-invoices. The exchanged e-invoice should include the original validated e-invoice, the validation link provided by the IRBM in the form of a QR code and a PDF copy.

The QR Code enables the verification of the existence and status of the e-invoice through the MyInvois portal.

Malaysia B2B e-invoicing

CTC Type
E-invoice reporting.

Network
E-invoices are processed via the MyInvois portal, however, they should be exchanged out-of-band.  

Format
XML or JSON.

eSignature Requirement
Not known at this time.

Malaysia B2G e-invoicing

CTC Type
E-invoice reporting.

Network
E-invoices are processed via the MyInvois portal, however, they should be exchanged out-of-band.

Format
XML or JSON.

eSignature Requirement
Not known at this time.

E-invoicing in Malaysia: Key requirements and regulations

From August 2024, Malaysian taxpayers with an annual turnover or revenue of more than RM100 million will be required to submit and clear e-invoices for certain transactions.

Malaysia e-invoicing adopts a continuous transaction control (CTC) approach. E-invoices must be submitted and cleared via MyInvois, the e-invoicing portal of the Inland Revenue Board of Malaysia (IRBM).

As of the 9 February 2024, the IRBM guidelines state that mandatory e-invoicing will be for specific sectors and transactions.

Sectors in-scope of mandatory e-invoicing include:

  • Automative
  • Aviation
  • Luxury good and jewellery
  • Construction
  • Licensed betting and gaming
  • Payments to agents, dealers and distributors

For cross-border transactions, Malaysian taxpayers must issue a self-billed e-invoice to document the expense, but foreign parties do not need to implement the Malaysia e-invoicing system.

B2C transactions fall outside of the e-invoice mandate. Any e-invoices for transactions not in scope are subject to the buyer’s request.

What is an e-invoice in Malaysia?

An e-invoice is a digital representation of a transaction between a supplier and a buyer that replaces all paper or electronic documents serving as invoices, credit notes and debit notes.

An e-invoice under the new framework is a structured file created in a defined format that can be automatically processed by the relevant systems.  The e-invoice structure includes 53 mandatory fields and must be submitted in either XML or JSON format.

An e-invoice will contain the same essential information as per current practices, such as supplier’s and buyer’s details, item description, quantity, price excluding tax, tax, and total amount.

Following the validation process, e-invoices must include an embedded QR code.  

PDFs, Doc, JPG and paper will not be considered as e-invoices.

What is the process flow of an e-invoice in Malaysia?

E-invoice issuance: Taxpayers must submit e-invoices to the IRBM via the MyInvois portal or through a third-party e-invoicing software API in XML or JSON format.

Validation: Once submitted, the e-invoice is validated in real-time and a Unique Identification Number, validation link (QR Code) and PDF format of the cleared e-invoice are sent to the supplier.

Validation notification: The IRBM performs certain validation checks on the e-invoice structure and on taxpayers identification numbers and notifies the buyer and supplier of the validated invoice.

E-invoice sharing: Suppliers should share the validated e-invoice and a visual representation with a QR code embedded. The QR code allows buyers to validate the existence and status of the e-invoice via MyInvois. It’s the supplier’s responsibility to share the document with the buyer.  

Rejection or cancellation: Optional rejection (buyer side) and optional cancellation (supplier side) requests have a 72 hour time limit, after which the invoice is considered valid. Any corrections or amendments made after the 72 hour limit will need to be made through credit, debit or refund notes.

Transaction Summary: A summary of the transaction can be viewed via the portal.

What are the types of e-invoices in Malaysia?

In Malaysia, the e-invoice mandate covers the below document types:

  • Invoice
  • Credit note
  • Debit note
  • Refund invoice
  • Self-billed invoice

E-reporting regulations in Malaysia

For all other transactions that fall outside of the mandatory e-invoicing scope, and where the buyer did not request an e-invoice to be issued, suppliers can issue an invoice or receipt as per the current practices (e.g. paper).

However, in these cases, suppliers are required to instead issue a consolidated e-invoice aggregating all invoices and receipts on a monthly basis, within 7 days of the month end-. Consolidated e-invoices are common in Malaysia today, and this requirement allows this practice to continue, while still giving the IRBM access to aggregated transaction data. These consolidated invoice reports are issued to a ‘general public’, without specification of each buyer, and a general TIN is provided.

A description of the products or services is provided by the summary of each receipt presented as separate line items in the consolidated e-invoice and/or the list of receipts (in a continuous receipt number) presented as line items.

Additionally, when consolidated- e-invoices are issued, MyInvois will send notifications back to the supplier only. Rejections are not allowed from the buyer side and suppliers are not required to share the validated e-invoice with buyers.

Consolidation cannot be used for self-billed invoices.

Implementation timeline

2015: Malaysia introduces voluntary e-invoicing

October 2022: The Malaysian Ministry of Finance announces plans for e-invoicing pilot program for select taxpayers

November 2023: Mandatory e-invoicing implementation timeline is delayed to August 2024

February 2024: Inland Revenue Malaysia publishes Software Development Kit and e-invoicing guidelines

August 2024: Mandatory e-invoicing and clearance in Malaysia for taxpayers with an annual turnover or revenue of more than RM100 million (aprox. 20 million euros)

January 2025: Mandatory e-invoicing for taxpayers with an annual turnover or revenue between RM25 million (aprox. 5 million euros) and RM100 million

July 2025: Mandatory e-invoicing for all taxpayers

For the latest updates and in-depth timeline bookmark our Malaysia e-invoicing system blog.

Setting up e-invoicing and
e-reporting in Malaysia

Malaysia’s e-invoicing mandate allows submission of e-invoices via a third-party API. Sovos’ e-invoice and e-reporting compliance solutions are suitable for Malaysia and other international tax requirements.

Speak with a Sovos expert to set-up e-invoicing in Malaysia.

Complete the form below to speak with one of our e-invoicing experts

FAQ

E-invoicing will become mandatory for certain transactions for taxpayers with an annual turnover or revenue of more than RM100 million from August 2024. Additional taxpayers will be in scope from 2025 with all taxpayers included by July 2025.

There is a consolidated e-invoice requirement for transactions where e-invoicing is not mandatory, and the buyer does not request an e-invoice to be issued. Taxpayers must aggregate all invoices and receipts issued and issue a consolidated e-invoice via the MyInvois, on a monthly basis (within 7 days from the month end).

E-invoicing is currently optional for taxpayers in Malaysia but an upcoming mandate will make it a requirement for all taxpayers by 2025. The first group of taxpayers need to comply by August 2024.

The Inland Revenue Board of Malaysia (IRBM) is the e-invoicing authority in Malaysia. The IRBM is responsible for the MyInvois Portal, the platform used to submit, clear and validate e-invoices in the country.

Taxpayers within scope of the e-invoicing mandate submit documents via the country’s MyInvois Portal for validating, before sharing with the buyer. The real-time e-invoicing process saves time and resources for businesses and facilitates cross-border and international trade.

Malaysia is one of many countries in Asia Pacific to adopt e-invoicing including , China, South Korea, Singapore, Japan and the Philippines.

e-invoicing in Poland: B2B, B2G, KSeF

The state of Poland’s e-invoicing requirements is in flux. While B2G transactions have required electronic invoices since April 2019, the country’s B2B e-invoicing rules were set to come into effect in July 2024 before a postponement was announced in January 2024. It can be hard to know the latest plans for new obligations, especially considering the possibility of postponements and rule changes.

Staying in the know is vital if your business is to avoid costly penalties.

Continue reading to learn about the current status quo of Poland e-invoicing, including the introduction of a Continuous Transaction Controls (CTC) system via the KSeF platform, as well as what you can expect going forward.

At a glance: Poland e-invoicing

Poland B2G e-invoicing

CTC Type
E-Invoice clearance via KSeF or PEF for B2G transactions carried out with public institutions, initially planned from 1 July 2024, due to the postponement announced in January 2024, the final date is still to be announced

Network
Possible e-invoice issuance both via PEF and KSeF. If B2G, e-invoice will be issued in PEF and automatically transferred to the KSeF in order to assign a KSeF number. The PEF invoice will be visible in the KSeF in the appropriate tab for PEF invoices, and the information about the assigned KSeF number will be available in PEF.

Format
PEF format or KSeF format supporting XML invoices following the logical structure FA_VAT.

eSignature Requirement
A qualified electronic signature is one of the means that taxpayers must use to authenticate in KSeF.

The integrity and authenticity of an invoice are ensured by issuing structured e-invoices via KSeF.

Archiving Requirement
10 years.

Poland B2B e-invoicing

CTC Type
E-Invoice clearance via KSeF for transactions carried out by registered VAT-taxable taxpayers, initially planned from 1 July 2024 and VAT-exempt taxpayers from 1 January 2025, due to the postponement announced in January 2024, the final dates are still to be announced

Network
Centralised network where the e-invoice exchange is processed through the KSeF platform provided by the Ministry of Finance.

Format
XML following the logical structure FA_VAT.

eSignature Requirement
Qualified electronic signature is one of the means that taxpayers must use to authenticate in KSeF.

The integrity and authenticity of an invoice are ensured by issuing structured e-invoices via KSeF.

Archiving Requirement
10 years.

E-invoicing regulations in Poland

Tax compliance is monitored and regulated by the Ministry of Finance, particularly the National Revenue Administration. After implementing the SAF-T changes in Poland in the form of JPKs, the Ministry of Finance is currently revolutionising the invoicing system, introducing the centralised platform Krajowy System E-Faktur (KSeF) for the transmission of structured e-invoices.

Since 2019, public entities in Poland have been mandated to receive and process e-invoices. While currently optional for suppliers of public entities, the transmission of e-invoices will be required for B2G and B2B transactions when the mandate is implemented (this was planned for 1 July 2024 until it was postponed in January 2024).

KSeF Poland: National Electronic Invoicing System

Poland has introduced a national electronic invoicing system called KSeF (Krajowy System e-Faktur), which is a centralised platform for issuing and exchanging electronic invoices with a structured format – currently logical structure FA (2). The go-live date for issuing and receiving invoices via KSeF has been postponed three times since it was originally announced. Once in action, buyers and suppliers in B2B and B2G transactions will be mandated to issue and receive e-invoices through the KSeF platform.

Poland B2B e-invoicing

The issuance of electronic invoices through KSeF has been voluntary for businesses since 1 January 2022, meaning suppliers can issue e-invoices via KSeF. However, buyers can still request to receive them in a different format outside of KSeF.

This will change when e-invoicing via KSeF becomes mandatory for the majority of businesses in Poland – namely registered VAT taxpayers who have fixed establishments on the territory of Poland, and in the later stages to VAT-exempt taxpayers.

Poland B2G e-invoicing

Poland’s own portal, PEF (Platforma Elektronicznego Fakturowania), has been in place since 2019. It aims to centralise and facilitate B2G e-invoice transmission allowing private companies and public bodies to issue and receive electronic invoices. All public entities in Poland have been obliged to register on PEF and receive structured e-invoices since 18 April 2019.

The PEF and KSeF systems will merge when the mandate enters into effect, meaning that e-invoicing in the B2G transactions will be possible both via PEF and KSeF. B2G invoices will also need to receive a KSeF unique ID.

For instance, taxpayers will be able to use features available in KSeF like semantic validation of the e-invoice. Tax authorities will be able to access such invoices, regardless of if they were issued through PEF or KSeF. Therefore, it will be possible to continue issuing B2G invoices via PEF and according to the PEF e-invoice standard.

Timeline: e-invoicing adoption in Poland

The implementation of e-invoicing in Poland has been done in stages. Here is a brief timeline of electronic invoicing’s adoption in the country:

  • October 2021: Testing period of KSeF begins
  • December 2021: Testing period of KSeF ends
  • 1 January 2022: Voluntary use of KSeF commenced
  • 17 June 2022: Poland received the derogatory decision from the VAT Directive to introduce mandatory e-invoicing via KSeF
  • 1 December 2022: Ministry of Finance published draft legislation amending the VAT Act regarding mandatory e-invoicing’s implementation
  • 15 March 2023: Poland publishes second draft law amending the VAT Act, including KSeF changes
  • 16 June 2023: the law amending VAT Act is published by the Ministry of Finance
  • TBD, earlier 1 July 2024: KSeF mandate enters into force for taxpayers
  • TBD, earlier 1 January 2025: KSeF mandate extends to VAT-exempt taxpayers

After the mandatory e-invoicing goes live, the administrative penalties for non-compliance will apply and it will no longer be possible to issue invoices using cash registers, the final date is still to be announced, due to the mandate postponement.

Refer to this blog for an in-depth timeline about e-invoicing in Poland.

Benefits of e-invoicing

While businesses will be legally required to use electronic invoices, there are benefits that taxpayers can enjoy when comparing e-invoices to traditional, paper invoicing. These include:

  • Cost savings: Reducing paper usage, postage and manual labour
  • Time savings: Electronic invoices use standardised formats and automated processes
  • Convenience:  e-invoices increase interoperability across businesses
  • Increased security: Authentication and validation ensure the authenticity of transactions and the according invoices

Learn more about Sovos’ e-invoicing solution.

How to choose the right e-invoicing software in Poland

It’s not enough to accept software that accommodates e-invoicing without adapting it to the often-changing local rules and standards, resulting in the new status quo right as it comes into effect.

While functionality is important, also consider the future when choosing your ideal e-invoicing software provider.

International businesses must keep their eye on the bigger compliance picture, looking beyond local mandates to ensure they are meeting their obligations everywhere they do business. This can be heavy on resources, especially when considering the scope for regulatory updates across multiple jurisdictions.

This is why it is key to work with a global provider such as Sovos.

Future of e-invoicing in Poland

The future of e-invoicing is clear: Poland is working towards a vast implementation. A mandate was planned for 1 July 2024, and while it was postponed in January 2024, it will still become a requirement for many taxpayers. However, the impending implementation of VAT in the Digital Age cannot be forgotten when considering the future of e-invoicing in Poland. Designed to digitise the VAT system in the EU, the proposal may deliver further changes to how established taxpayers in the country do business.

The future of e-invoicing and tax as a whole may be uncertain across the European Union, but Sovos can provide your organisation with the consistency and peace of mind you require. Bookmark this page to remain updated with the latest developments that may affect how you do business.

Additional obligations for VAT compliance in Poland

Keeping on top of the upcoming e-invoicing requirements is important, but it’s also crucial to remember other obligations your business may face when complying with Poland’s VAT regulations.

While adapting to the pressure of implementing e-invoicing, taxpayers need to remain mindful of overall VAT Compliance and the current SAF-T mandate in Poland.

The results of non-compliance can change businesses forever, but Sovos is here to help you stay on top of your obligations.

Setting up e-invoicing in Poland with Sovos

Sovos prides itself in its continuous transaction controls (CTC) software which is purpose-built for customers who must remain on top of tax obligations wherever they do business – even as regulations change in the future.

Taxpayers established in Poland will be starkly aware of the evolving demands of compliance, with B2B and B2G transactions eventually requiring electronic invoices.

As CTCs and e-invoicing rise in prominence globally, there has never been a better time than now to find a compliance partner who understands the rules in play and is already looking ahead at what’s to come. Sovos is the provider you can trust.

The Sovos e-invoicing compliance solution was put to work by Brown-Forman, which looked to ease the burden of compliance from its IT department. Brown-Forman was able to reallocate its resources to core business functions with peace of mind, knowing that Sovos was there to ensure its e-invoicing requirements were being met.

Get in touch with us

FAQ

E-invoicing is mandatory in Poland for B2G transactions, when supplying goods or services to public sector entities that have an obligation to receive e-invoices. This is going to change, when B2B and B2G e-invoicing will be obligatory via KSeF, the final date is still to be announced.

Taxpayers will be mandated to electronically report specific information through KSeF , e.g. in cross-border transactions. In practice, e-invoicing and e-reporting are performed in the same way. The final date of introducing mandatory e-invoicing in Poland is still to be announced, after Ministry of Finance conducts the technical audit of the KSeF system.

Sovos has the first global solution for e-invoicing compliance, including e-reporting functionality.

Poland’s VAT Act mandates that invoices must be issued in two copies, with one being sent to the customer. Invoices cannot be raised before 30 days of the date of the delivery of the goods or services, but also no later than 15 days after the month they were delivered.

VAT invoices must contain numerous details as required by the tax authority, including the likes of:

  • Date of issuance
  • A unique identification number
  • Full name and address of buyer and seller
  • Description of type and quantity of supplied goods, or type and extent of rendered services
  • Date of transaction
  • VAT rate and amount payable

With the implementation of mandatory e-invoicing, additional data points are required to comply with the invoice schema.

Sending and receiving electronic invoicing for B2B and B2G transactions via KSeF in Poland will become mandatory. It was planned to go live on 1 July 2024, though it was postponed in January 2024.

KSeF (Krajowy System e-Faktur) is Poland’s national electronic invoicing system, which is a centralised platform for issuing and exchanging electronic invoices. E-invoices have to follow a structured format, currently logical structure FA (2).

QR codes will be mandatory on the graphical representation of the invoices shared outside of KSeF with the counterparties, invoices issued in the offline modes and VAT RR and VAT KOR RR invoices.

Currently, e-invoicing via KSeF and SAF-T will work parallel with each other in Poland.

VAT Compliance in Poland: An Overview for Businesses

Poland VAT compliance can be a tall task for those yet to devise a future-proof strategy. Considering legislation changes frequently and the ongoing phased implementation of e-invoicing, it takes a lot of time, money and energy to meet your obligations.

This is your overview of all the tax compliance rules applicable in Poland, covering mandates and requirements such as VAT, SAF-T (JPK) and e-invoicing via KSeF. Add this page to your compliance toolbelt so you can understand and meet your obligations – both now and in the future.

VAT obligations in Poland

There are several tax obligations in Poland that taxpayers must be mindful of. These include:

Poland: Insurance Ombudsman Contribution

While Poland does not have an Insurance Premium Tax (IPT) regime, it does have some parafiscal charges that are applicable to the insurance premium.

The Fire Brigade Tax (FBC) is applicable in special cases. There is also a so-called Financial Ombudsman Charge (FOC) to be settled online and paid to the Polish Financial Ombudsman Office on a yearly basis. This charge is applicable for all insurance companies operating under Freedom of Services (FOS) or Freedom of Establishment (FoE) in Poland as well as for Domestic Insurance Companies.

Previously, Insurer Ombudsman Charge (IOC) applied to all 18 classes of non-life insurance and life insurance policies. It was replaced by the Financial Ombudsman Charge (FOC) in January 2023.

Import VAT in Poland

The act of importation is a taxable event for which VAT is chargeable in Poland.

There is an option to use postponed accounting on imports. Poland introduced the option to defer import VAT as of 1 July 2020, enabling businesses to declare the tax through the VAT return without any cash payment. This mechanism is a great cash flow for the company as it doesn’t have to advance the VAT at Customs.

Taxable persons can use the mechanism, irrespective of whether the goods are subject to simplifications from the EU Customs Codes. To use the deferment mechanism, taxpayers must have a clear history of recent VAT compliance.

Invoicing requirements in Poland

Polish VAT invoices must be issued no later than the 15th day of the month after the taxable supply, and no earlier than 30 days before the supply of goods or completion of a service.

The electronic invoice will be considered issued on the day it is sent to KSeF, i.e. at the moment when it enters the system. When a structured invoice is assigned a KSeF number (unique ID), which contains the date of issue, it becomes legally valid. The issuance date is also in the Official Receipt Certificate (UPO).

To learn more about e-invoicing requirements in Poland, read our dedicated Poland e-invoicing overview.

Registration for OSS in Poland

One Stop Shop (OSS) has been effective in Poland since 1 July 2021, aiming to simplify VAT obligations for companies involved in distance selling.

Its main benefit is that a supplier can choose to account for the VAT due under OSS, which can be used for intra-EU cross-border supplies of goods and all cross-border supplies of services made to final consumers in the EU.

As a result, the company is required to register for VAT in only one EU Member State instead of registering for VAT in all EU Member States in which it operates – provided that the pan-EU threshold of EUR 10,000 in intra-EU distance sales to consumers is exceeded.

OSS can be used by businesses established in and outside the EU. If a supplier or a deemed supplier decides to register for OSS, it must declare and pay VAT for all supplies (goods as well as services) that fall under OSS.

Where the Member State of identification is Poland, the taxable person is entitled to file a notification to II Urzad Skarbowy Warszawa Srodmiescie by electronic means.

The forms for the EU OSS procedure are as follows:

  • VIU-R – notification form
  • VIU-DO – Form of the return for VAT settlements, filed for each quarter by the end of the month following a given quarter

The forms for non-EU OSS procedure are as follows:

  • VIN-R – Notification form
  • VIN-DO – Form of the return for VAT settlements, filed for each quarter by the end of the month following a given quarter

If you need help, please contact us or find more information on our dedicated guide.

Registration for IOSS in Poland

Import One Stop Shop (“IOSS”) is effective as of 1 July 2021 and applies to B2C distance sales of goods from outside the EU.

Under the standard procedure, VAT is due on all commercial goods imported into the EU Member State (the country of destination).

The purpose of IOSS is to facilitate the declaration and payment of VAT due on the sale of low-value goods of consignment valued at less than EUR 150. If the IOSS is used, the importation into the EU is exempt from VAT.

When using IOSS in Poland, a taxable person without a registered seat in the territory of the EU must indicate Poland as the Member State of identification. The taxable person in charge of the supply, or the intermediary, is entitled to file a notification with the II Urzad Skarbowy Warszawa Srodmiescie electronically.

The forms for the IOSS procedure are as follows:

  • VII-R – Notification form of taxable person
  • VII-RP – Notification form of intermediary
  • VII-DO – Form of the return for VAT settlements, filed for each month by the end of the month following a given month

If you need help, please contact us or find more information on our IOSS overview.

Intrastat and EC Sales list in Poland

Intrastat is an obligation for certain businesses that trade internationally in the European Union, relating to the movement of goods across EU Member States.

While the requirements remain similar across the region, certain Member States have implemented rules differently and each has its own Intrastat threshold for reporting. Poland’s declaration threshold for 2024 is PLN 6.2 million for arrivals and PLN 2.8 million for dispatches.

Find out more with our Intrastat guide.

VAT compliance in Poland FAQ

The standard procedure for VAT returns in Poland includes monthly filing. Taxpayers deemed as ‘small’, however, can file VAT returns quarterly if they meet specific requirements. VAT returns can be submitted by the official portal or through approved software.

VAT returns need to be filed by the 25th of the month following the accounting period. This is of utmost importance as taxpayers can be financially penalised for failing to meet the deadline, as well as the potential to accrue statutory interest and potentially face legal proceedings.

Since October 2020, there has been a Uniform Control File (JPK_VAT) that is made up of a record section and a declaration section. This consolidates data that was included in VAT returns prior to the file’s introduction.

There is a host of required information that must be included on invoices, including (but not limited to):

  • Date of issuance
  • Customer’s VAT ID number
  • Full name and address of both the supplier and customer
  • Description of quantity and type of goods supplied, or type and extent of services rendered
  • Date of transaction (or payment)
  • VAT rate applied and VAT amount payable

With the implementation of mandatory e-invoice, additional data points are required to comply with the invoice schema.

Unit price of goods or services

The standard VAT rate in Poland is 23%, though certain goods and supplies have reduced rates of 8% and 5% and some services are exempt from VAT altogether.

The VAT registration threshold for companies established in Poland is PLN 200,000.

There is no threshold on the VAT registration for foreign companies not established in Poland; they are required to register for VAT prior to making their first VAT-relevant supply in the country.

VAT applies to the supply of goods and rendering of services in Poland for consideration. VAT liability is money owed to the tax authority and is calculated by subtracting credits from the total amount of VAT a taxpayer has collected at the moment the VAT becomes chargeable.

The deadline for making the relevant VAT payment is the same as for submitting the VAT return part of the SAF-T, i.e., by the 25th day of the month following the month in which the tax point arises. VAT liabilities must be paid by bank transfer and in Polish zloty.

The Polish Tax Authorities require businesses established outside of the EU and having a VAT registration in Poland to appoint a fiscal representative in Poland. The fiscal representative can be an individual or a company, such as Sovos. The fiscal representative is jointly and severally liable with the taxpayer for the tax liability, which the fiscal representative settles on behalf of and for the benefit of that taxpayer in Poland.

It is worth noting that, since 23 February 2021, taxpayers established in Norway or Great Britain have not been obliged to appoint a fiscal representative when operating in Poland. The companies established in both Norway and Great Britain can register directly for VAT purposes in Poland. This entails that the legal representative of the company can sign the registration form without any involvement from the Polish established Company or an individual acting in the capacity of a fiscal representative.

An EU business is not required to appoint a fiscal representative to register for VAT in Poland, but it may choose to do so.

VAT applies to the following transactions in Poland:

  • The supply of goods and services within Poland for consideration
  • The export of goods outside of the EU
  • The import of goods from non-EU Member States
  • Receipt of reverse-charge services by a taxable person in Poland
  • Intra-Community supply of goods
  • Intra-Community acquisitions of goods from another EU Member State by a taxable person

The following activities are outside the scope of Polish VAT:

  • Transactions that cannot be subject to legal agreements (illegal transactions)

  • Sales of businesses (transfers of going concerns or part thereof)

The threshold for VAT registration for Polish-established businesses is PLN 200,000 (about EUR 46,000).

The VAT registration limit may apply either:

  • Retrospectively: The value of supplies of goods or services exceeded PLN 200,000 in the preceding tax year
  • Prospectively: At the start of business, the value of supplies of goods or services is expected to exceed PLN 200,000

Businesses operating in Poland may additionally opt to register for VAT regardless of reaching the threshold or if their operations comprise only VAT-exempt activities.

Non-established businesses – foreign businesses without a place of business in Poland – must register for VAT in Poland when making taxable supplies of goods or services in Poland. They are exempt from registration when they exclusively supply the following services:

  • Services and goods where the Polish purchaser pays tax under the reverse charge mechanism
  • Certain services that are subject to a zero rate (e.g., services supplied within Polish seaports, connected with international transport, services of air traffic control rendered for foreign providers of air transportation)

How Sovos can help with VAT compliance in Poland

The varied nature of tax obligations in Poland means compliance can be a resource-heavy task – especially when you consider the high probability of future updates and implementations. Choosing Sovos, a single vendor with global and local tax expertise, allows you to future-proof compliance.

Reclaim your time so you can focus on growing your business by speaking with our expert team today. Compliance is our concern.

VAT Compliance in Romania: An Overview for Businesses

Romanian VAT Compliance can be described as a layered system conflated with different declarations and requirements, from SAF-T obligations to electronic invoicing. In this page, businesses aiming to remain compliant and looking to know the most up to date news, can find an overview of the main Romanian VAT rules. Scroll down to learn about Romanian VAT compliance requirements and how to remain compliant.

Romania: General VAT information

Romania is a complex country for VAT rules, with many elements that companies need to be aware of. These include:

Periodic VAT return (Decont de taxa pe valoarea adaugata)

Monthly
25th day of the month following the end of the tax period

Quarterly
25th day of the month following the end of the tax period

Romanian Domestic Supplies & Purchase listing (Declaraţie informativă privind livrările/prestările şi achiziţiile efectuate pe teritoriul national – D394)

Monthly
30th day of the month following the end of the tax period

SAF-T (Declarației informative D406)

Monthly/Quarterly

SAF-T Stocks (Declarației informative D406)

On-demand – a minimum 30-day deadline

SAF-T Assets (Declarației informative D406)

Deadline for the submission of Financial Statements for the year

EU Sales and Purchases List

Monthly
25th day of the month following the end of the tax period

Intrastat

Monthly
15th day of the month following the relevant month

VAT rates

19%
9%
5%
0% and Exempt

Intrastat thresholds

Arrivals: RON 1 million
Dispatches: RON 1 million

VAT rules in Romania

Romania is at the forefront of VAT compliance, having implemented a broad range of requirements, from SAF-T obligations to e-invoicing. You can find more information on the various rules and requirements here:

Requirements to register for VAT in Romania

Taxable persons established in Romania are required to register for VAT purposes if their annual turnover exceeds the threshold RON 300,000 (EUR 88,500). Established entities that don’t meet the threshold may opt to register for VAT purposes.

Non-established entities are required to register for VAT purposes, regardless of annual turnover, when practicing certain activities such as Intra-Community transactions or exports.

When does VAT liability apply in Romania?

In Romania, VAT liability encompasses various transaction types – including, but not limited to, the following:

  • Supplies of goods and services for consideration with place of supply in Romania
  • Imports of goods
  • Intra-Community acquisitions of goods

Invoicing requirements in Romania

Legislation in Romania states that invoices, paper or electronic, must include the following information:

  • Invoice unique serial number
  • Invoice/delivery date
  • Supplier identification
  • Recipient identification (when they are taxable subjects as well)
  • Description of the goods or services provided
  • Taxable amount
  • Applicable tax rate

Since January 2024, the Romanian B2B e-invoicing and e-reporting mandate has applied to established taxpayers and VAT registered entities – concerning all B2B transactions with place of supply in Romania.

From January 2024, VAT-registered entities must report their invoices (regarding domestic B2B transactions) to the RO e-Factura platform within five working days of issuance.

Established taxpayers are equally required to electronically report their invoices from January 2024.

The tax authority provided a three-month grace period where no penalties will apply, meaning that penalties will be imposed from April 2024.

From July 2024, the e-reporting obligation will shift to an e-invoicing requirement for transactions between established taxpayers. If established taxpayers fail to issue the invoice electronically, the invoice must be reported within five calendar days to the RO e-Factura platform.

In addition to the invoicing content requirements, which must also be included in electronic invoices, the e-invoice must comply with certain technical requirements as well.

You can find more information about Romania’s e-invoicing rules on our dedicated Romania e-invoicing page.

Registration for OSS in Romania

The EU established the One Stop Shop (OSS) in July 2021, implementing an EU-wide 10,000-euro threshold for VAT and simplifying cross-border online sales in the region simpler. This is part of the EU VAT e-commerce package.

Following the applicable Romanian VAT rules, the following fall within the scope of the OSS regime:

  • Entities established in Romania
  • Non-EU taxable persons with a fixed establishment in Romania
  • Entities which have fixed establishments in more than one EU Member State including Romania)

These entities may choose Romania as their Member State of registration for OSS purposes.

Non-EU entities, which do not have a fixed establishment in the European Union, may also register in Romania for OSS purposes – only if carrying out distance sales of goods when the goods are dispatched from Romania or any other EU Member State.

In addition to the OSS registration, taxable persons may also apply to the Import One-Stop Shop (IOSS) in Romania which concerns B2C distance sales of goods from outside the region.

Intrastat, EU Sales and Purchases List and Domestic Supplies & Purchase listing (form 394) in Romania

Intrastat returns – which are related to the movement of goods in the European Union – are submitted in Romania if the taxable person exceeds the provided threshold.

Even though Intrastat requirements remain similar across the EU, each Member State may implement rules differently. Our Intrastat Guide is a useful tool for navigating cross-border trading in the EU.

In Romania, the Intrastat threshold for both arrivals and dispatches of goods is RON 1,000,000 (around EUR 201,000). The Intrastat return must be submitted by the 15th day of the following month.

The EU Sales and Purchases List is submitted in Romania by taxable persons carrying out Intra-Community supplies or purchases of goods or certain services. The return must be submitted by the 25th day of the following month and is not required to be submitted in tax periods where no transactions occurred.

The Domestic Supplies & Purchase listing (form 394), first implemented in July 2014, is an additional return to be submitted periodically by all VAT-registered entities in Romania. The return includes data on domestic supplies and purchases between VAT-registered entities and must be submitted by the 30th day of the month following the end of the tax period.

FAQ VAT compliance in Romania

In Romania, any entity subject to taxation (not just VAT) shall receive a tax identification number.

The number of digits in the VAT number may vary.

The Romanian periodic VAT return – Decont de taxa pe valoarea adaugata – is submitted on a monthly or quarterly basis, if the taxpayers’ annual turnover remains below the equivalent in RON of 100.000 EUR. The returns must be submitted electronically by the 25th day of the month following the end of the applicable tax period.

The VAT return must include the amount of the deductible VAT as well as the VAT charged in the tax period.

Taxable persons established in Romania are required to register for VAT purposes if the RON 300.000 (EUR 88.500) annual turnover threshold is exceeded. There is no threshold for non-established entities.

The Romanian VAT Act is part of the Fiscal Code (Codul Fiscal) of 8 September 2015, adopted by Law no. 227/2015.

The applicable VAT rates in Romania are 19%, 9%, 5% and 0%.

As a rule, the standard rate of 19% applies to all supplies of goods and services.

The reduced rates of 9% and 5% are only applicable to certain specifically identified goods and services. The 9% rate applies to:

  • Medicines for human and veterinary use
  • Food supplies
  • Hotel accommodation
  • Restaurant and catering

The reduced rate of 5% is applicable to:

  • Books, newspapers, magazines and school manuals
  • Access to museums, castles, cinemas, zoological and botanical gardens
  • Passenger transport

Exceptionally, certain transactions are taxable at a 0% rate, namely:

  • Exports of goods
  • Intra-community supplies of goods

Romania’s VAT rules provide reduced VAT rates of 9% and 5%, depending on the goods and services in question.

Taxable persons not established in the EU that fall under the obligation to register for VAT purposes in Romania are obliged to appoint a fiscal representative.

Yes. Since January 2023, Romania‘s mandatory e-transport system has monitored the transport of certain goods in the national territory. The e-transport system operates in parallel with Romania’s e-invoicing system. For more information read our in-depth blog about the e-transport system in Romania.

Help for VAT compliance in Romania

Looking back at this overview, it becomes clear just how fast-paced Romania’s developing VAT compliance requirements are. Sovos helps customers navigate difficult VAT compliance landscapes worldwide, by leveraging our global coverage.

We take care of compliance so you can concentrate on growing your business.

Dominican Republic e-invoicing

The Dominican Republic is just one of the many nations that are turning to e-invoicing. From 2024, established taxpayers will be required to meet strict new rules for how they execute business transactions.

Understanding what’s to come is vital, as is choosing a partner with the technical know-how and foresight to ensure compliance during change. Bookmark this page to stay updated with developments in e-invoicing in the Dominican Republic, written by regulatory experts.

At a glance: e-invoicing in the Dominican Republic

Dominican Republic B2G e-invoicing

CTC Type
E-invoice clearance according to the calendar, starting with the first group in May 2024

Network
The system’s web services are a set of protocols and standards that, using extensible markup language (XML) and REST API, allow the exchange of data between the heterogeneous invoicing software of taxpayers and the tax authority through an environment defined as {Environment}, finding various services in electronic invoicing

Format
Electronic invoices will be sent in an XML file, which consists of a plain text record that uses a series of custom tags to describe both the structure and other characteristics of the document

eSignature Requirement
A digital certificate for Tax Procedure, issued and signed digitally, by a certification entity authorised by INDOTEL or a certificate with an institutional link is required

Archiving Requirement
10 years

Dominican Republic B2B e-invoicing

CTC Type
E-invoice clearance according to the calendar, starting with the first group in January 2024

Network
The system’s web services are a set of protocols and standards that, using XML and REST API, allow the exchange of data between the heterogeneous invoicing software of taxpayers and the tax authority through an environment defined as {Environment}, finding various services in electronic invoicing

Format
Electronic invoices will be sent in an XML file, which consists of a plain text record that uses a series of custom tags to describe both the structure and other characteristics of the document)

eSignature Requirement
A digital certificate for Tax Procedure, issued and signed digitally, by a certification entity authorised by INDOTEL or a certificate with an institutional link is required

Archiving Requirement
10 years

E-invoicing regulation in the Dominican Republic

The electronic invoicing regulation in the Dominican Republic was published on 17 May 2023 and lays out the specific expectations and requirements for taxpayers.

Firstly, the e-invoicing regulation applies to natural and legal persons, both public and private. It also applies to entities without legal personality domiciled in the Dominican Republic that carry out the transfer of goods, delivery in use or provision and lease of services for consideration or free of charge.

All issuers of electronic invoices are to be recognised and authorised as such by the DGII and have a digital certificate for Tax Procedure issued by an entity authorised by the Dominican Institute of Telecommunications (INDOTEL).

Electronic invoices must be compliant with a set format and are to be sent to the authority and electronic receiver. Each e-invoice will have a Printed Representation (RI) of the electronic tax receipts (e-CF) which will be delivered physically to exceptional non-electronic receivers.

The regulation outlines three forms of acceptable e-CF issuance:

  • Using self-developed systems, following authorisation from the DGII
  • Using e-invoicing service providers that have been certified for compliance
  • Using the DGII’s free technological facility (known as free billing)

Find more details on the e-invoicing regulation in the Dominican Republic.

Timeline: e-invoicing adoption in the Dominican Republic

It can be difficult to stay informed about the changes to e-invoicing’s implementation in the Dominican Republic. This simple timeline details the key developments:

  • February 2019: Pilot phase for e-invoicing commences with 11 large companies
  • September 2022: Draft law filed for the Senate’s approval
  • 17 May 2023: The Electronic Invoicing Law of the Dominican Republic was published in the Official Gazette
  • 18 May 2023: The e-invoicing mandate became applicable across the nation
  • 15 January 2024: Group 1 of large national taxpayers need to have implemented e-CF by now
  • 15 March 2024: Group 2 of large national taxpayers need to have implemented e-CF by now
  • 15 May 2024: Group 3 of large national taxpayers and Government Institutions classified as Large National Taxpayers need to have implemented e-CF by now
  • 15 May 2025: E-invoicing will become a requirement for large local and medium-sized taxpayers
  • 15 May 2026: E-invoicing will become a requirement for small, micro, unclassified taxpayers and the remaining Government Institutions

Who must use an e-invoice in the Dominican Republic?

Both issuing and receiving electronic invoices are currently voluntary for both B2B and B2G transactions in the Dominican Republic. This will change in 2024 when the first wave of mandatory requirements rolls out, specifically to large taxpayers.

View the timeline below to find out exactly when e-invoicing will be obligatory for different taxpayer groups.

How to choose the right e-invoicing software in the Dominican Republic

The impending launch of electronic invoicing in the Dominican Republic brings along the need to find a system and strategy that works. Strategy isn’t one-size-fits-all; compliance is imperative and, subsequently, so is finding a solution that understands your company.

Sovos is a global compliance partner for organisations of all shapes and sizes, and our solutions not only help you to comply but also free up resources so you can focus on what really matters.

Another aspect of compliance to be mindful of is that requirements change. It’s unavoidable. Instead of jumping between solutions, organisations that partner with Sovos have peace of mind that they will be compliant in the present and meet any new demands that come in the future.

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FAQ

e-CF, otherwise known as an electronic tax receipt, is the Dominican Republic’s version of an electronic invoice. Taxpayers must submit e-CFs to the nation’s tax authority, DGII, for approval.

Once you have issued an electronic invoice, request an e-CF sequence and the DGII will validate the file. Once the tax authority has validated the e-CF, you will receive authorised versions.

The different statuses for e-CF are as follows:

  • Accepted e-CF – The document has been received and is valid
  • Rejected e-CF – The document has been received but is not valid
  • e-CF not found – The sequence is valid but has not been submitted to the Internal Revenue Service
  • In process – The document is being validated by the DGII

Regarding e-invoicing in the Dominican Republic, the Acknowledgement of Receipt only confirms that the electronic invoice has been received. The Commercial Approval indicates whether the e-CF has been accepted or rejected.

Romania e-invoicing

E-invoicing in Romania is developing fast. With a current B2G and High Fiscal Risk B2B mandate already in place and a new obligation facing all companies with operations in Romania from 1 Jan. 2024, it can be hard to stay on top of your business’ requirements. Failing to comply with Romania’s e-invoicing and e-reporting mandates will result in penalties, but more importantly, it will lead to invalid tax invoices – which don’t allow for VAT deduction – and, ultimately, may also trigger protracted tax audits, so it is crucial that you are aware of your requirements.

Read on to learn about the current state of Romania e-invoicing – from continuous transaction controls (CTC) and e-Factura to B2B e-invoicing developments – and what’s to come.

At a glance: Romania e-invoicing

Romania B2G e-invoicing

CTC Type
E-invoice clearance coupled with e-reporting requirements for transactions carried out between January and July 2024 with public institutions

Network
Centralised network where the e-invoice exchange is primarily processed through the RO e-Factura platform

Format
UBL 2.1 XML format file following CIUS RO national validation rules

eSignature Requirement
Digital Seal applied by the Ministry of Finance

Romania B2B e-invoicing

CTC Type
E-invoice clearance coupled with e-reporting requirements for transactions carried out by VAT-registered entities

Network
Centralised network where e-invoice exchange is primarily processed through the RO e-Factura platform

Format
UBL 2.1 XML format file following CIUS RO national validation rules

eSignature Requirement
Digital Seal applied by the Ministry Of Finance

Archiving Requirement
10 years

E-invoicing and e-reporting regulations in Romania

Romania introduced e-invoicing on a voluntary basis in November 2021 for B2G and April 2022 for B2B transactions. Romania’s Government Emergency Order no. 120/2021 implemented the RO E-Factura platform, the country’s e-invoicing system.

From July 2022, e-invoicing became mandatory for B2G and B2B transactions of so-called ‘high fiscal risk products’ following article II of Law no. 139/2022.

Romania applied for a derogation from the EU VAT Directive, aiming to implement a broader B2G and B2B e-invoicing and e-reporting mandate. The EU Council granted derogation in July 2023, allowing Romania to implement mandatory e-invoicing from 2024. The enacting of Law no. 296/2023 provides a new B2G and B2B e-invoicing mandate coupled with e-reporting requirements.

What is RO e-Factura?

RO e-Factura was officially launched in November 2021 as a voluntary clearance program for e-invoices, devised in an effort to streamline Romania’s tax collection. Users of e-Factura issue and submit their electronic invoices in a structured XML format through the system. Invoices are then cleared (following certain schema checks) and a digital seal is applied.

The RO E-Factura platform enables the automatic exchange of electronically issued invoices between entities registered in the system.

Romania B2B e-invoicing and e-reporting

B2B e-invoicing is already in play for transactions that include products deemed a high tax risk, including:

  • Fruit and vegetables
  • Alcoholic beverages
  • Mineral products
  • Construction materials
  • Clothing and footwear

Following the recently published mandate, B2B e-invoicing requirements will extend to all products. From January 2024, established and VAT-registered entities are required to report B2B domestic transaction invoices to the RO E-Factura platform within five days of issuance. From July 2024, invoices issued in transactions between established entities must be issued electronically through the RO E-Factura platform.

If, however, taxpayers fail to issue the invoice electronically through the RO E-factura platform, they are obligated to submit it to the RO e-Factura platform within five calendar days.

Romania B2G e-invoicing

From 1 July 2022, Romanian taxpayers were obliged to issue e-invoices, submitting them through the RO e-Factura system, when conducting business with the public sector. This obligation was namely within the context of certain public procurement contracts.

Romania’s e-invoicing mandate has expanded the scope of B2G invoicing in Romania which will apply to all transactions with public institutions from 2024.

Romania e-Transport system

Romania’s e-Transport system, often referred to as RO e-Transport, is used to monitor products when they are being transported. Coupled with the implementation of the CTC mandate, this is another reform that the nation has devised as part of its plan to combat tax fraud and evasion.

The application procedure of the RO e-Transport system has been approved by the joint Order of the National Agency for Fiscal Administration (ANAF) and the Romanian Customs Authority (AVR) no. 1190/4625/2022, with penalties applicable from October 2022.

The RO e-Transport system requires taxpayers to declare the movement of goods from one location to another, in advance of said movement. Once declared, it issues a number on the transport documents which is to be verified by authorities en route.

Read more about the e-transport system.

Timeline: e-invoicing & e-reporting adoption in Romania

The implementation of e-invoicing in Romania has been done in stages. This is a brief timeline of its adoption:

  • March 2020: E-invoicing system e-Factura is launched as a pilot program.
  • October 2020: Government Emergency Ordinance (GEO) no. 120/2021 introduced the legal framework for the implementation of e-Factura.
  • November 2021: Start of the voluntary phase for issuance of e-invoices for B2G transactions.
  • April 2022: Invoices for B2B transactions of high fiscal risk transactions can be voluntarily submitted in e-Factura.
  • July 2022: It is now mandatory to issue invoices for B2B transactions of high fiscal risk products through the RO e-Factura platform.
  • January 2024: For B2B transactions, established taxable persons and VAT registered entities must report invoices in the e-Factura system within five days of issuance.
  • April 2024: End of three-month grace period for e-invoicing mandate. Penalties will apply to non-compliant taxpayers.
  • July 2024: The system will shift to an invoice clearance system for B2B transactions between established taxpayers.

Benefits of e-invoicing

From a business perspective, e-invoicing offers several benefits when compared to traditional invoicing. Benefits may include:

  • Saving costs by reducing paper, postage and manual labour
  • Saving time by using structured, automated electronic systems and processes
  • Increased compatibility and interoperability across businesses with initiatives like PEPPOL
  • Enhanced security can be achieved with the validation and authentication of systems like e-Factura

How to choose the right e-invoicing software in Romania

Considering the ever-evolving nature of regulations and mandates surrounding newer technologies and platforms like RO e-Factura, it is important that your business identifies and utilises the right software. The cost of using e-invoicing software that does not update with changes to regulations is not desirable for any organisation.

Setting up e-invoicing and e-reporting in Romania with Sovos

Get in touch with a Sovos expert to explore setting up e-invoicing and e-reporting in Romania.

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Future of e-invoicing in Romania

The future of e-invoicing in Romania has already arrived. Following the EU Council’s derogatory decision to allow Romania to implement mandatory e-invoicing, Romania published a more comprehensive B2B mandate with a 2024 roll-out date. The new law requires businesses to issue structured electronic invoices for transactions to both business and public sector entities, and it applies to established and VAT-registered entities.

The looming implementation of VAT in the Digital Age in the EU may deliver more changes in Romania, however. Aiming to digitise the European VAT system, this proposal is generating a lot of uncertainty for businesses that conduct operations in the EU as it includes requirements for digital reporting and e-invoicing – as well as changes to VAT registration

While the future of tax in the European Union may be uncertain, you can rely on Sovos to help you navigate the digital landscape. Bookmark this page to stay up to date with the latest developments.

Additional obligations for VAT compliance in Romania

While it’s important to ensure your business complies with Romania’s e-invoicing requirements should it qualify, there are other obligations that require attention – including general VAT Compliance and the Romanian SAF-T mandate.

The cost of non-compliance may be severe, but our materials and experts can be the helping hand you need to ensure you are meeting your obligations.

FAQ

E-invoicing will be mandatory for all B2B transactions in Romania from 1 July 2024, adding to the existing electronic invoicing requirements for B2G and high fiscal risk B2B transactions.

Between January and June 2024, established entities are required to report their B2B invoices to the RO e-Factura platform within five days of issuance. This reporting obligation applies to VAT-registered entities from January 2024 onwards.

There are numerous requirements for invoices in Romania, including:

  • Date of issuance
  • VAT number of both supplier and customer
  • Full name and address of both supplier and customer
  • Full description of applicable goods or services, including quantities
  • The net supply value
  • The gross invoice value
  • The applicable VAT rate

The Romanian e-Factura is a clearance system which sees e-invoices sent, cleared and received through the central platform.

Should a taxpayer in scope of the e-invoicing and e-reporting mandate not comply with its e-invoicing obligations, they may receive a fine. From April 2024 (at which time the 3-month grace period ends) 2024, large non-compliant taxpayers may be fined between 5,000-10,000 RON, and others may expect a financial penalty between 500-2,500 RON, when failing to meet the e-reporting requirements set forth. From July 2024, non-compliance with the with the issuance and receipt of e-invoices will result in a fine equal to 15% of the total invoice amount.

E-invoice and e-report in Romania with Sovos

Sovos’ continuous transaction controls (CTC) software was purpose-built to help customers stay on top of their obligations, wherever they do business, even as the rules change.

As CTCs and e-invoicing continue to grow in global adoption, it is vital to partner with a provider that closely monitors the decisions of tax administrations and understands the regulations you face. Sovos can help.

One of the largest spirits companies in the world, Brown-Forman turned to Sovos for help with several challenges it was facing surrounding changing e-invoicing regulations. The company needed a solution that would monitor and implement the fiscal requirements of the countries it operated in.

With Sovos e-invoicing compliance in place, Brown-Forman was able to redeploy its resources to core business functions knowing that its e-invoicing requirements were being met – both in the present and the future.

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Romania SAF-T declaration

Since 2022, medium and large taxpayers in Romania have had to report their VAT electronically to the tax authority under the international standard known as SAF-T (Standard Audit File for Tax).

Romania implemented SAF-T to improve the data it receives in VAT returns, requiring more granular detail that is reported in real time. As well as benefiting the Romanian tax authority, the electronic submission of the D406 streamlines tax compliance and reporting for businesses.

The legal framework of SAF-T in Romania

The SAF-T mandate in Romania has been introduced through the amendment of the Fiscal Procedure Code, which foresees the obligation for taxpayers to submit a declaration containing information from the accounting and tax records.

The Fiscal Procedure Code also determines that the submission of the SAF-T file must be done electronically, leaving the remaining conditions to be determined by order of the ANAF.

Accordingly, ANAF has issued Order No. 1783, of 4 November 2021, which introduced the SAF-T reporting requirement from 1 January 2022. The Order provided the SAF-T Form D406, as well as the legal deadlines for submitting the various SAF-T files and the procedure and conditions for submission.

In these terms, the D406 file must be submitted electronically by generating an XML format file, which is submitted to a validation procedure, and preparing the corresponding D406 Form in PDF format.

The various SAF-T files can be submitted monthly, quarterly, annually and on-demand, depending on the VAT regime applicable to the taxpayer as well as on the type of file being submitted.

How to declare tax information with the SAF-T in Romania

Transaction and accounting data must be reported through Declaratiei Informative D406. Taxpayers are required to submit the information electronically in PDF format with an XML attachment and electronic signature.

What information must be declared to the ANAF?

The Romanian SAF-T file, the D406, is comprised of five sections:

  1. General Ledger
  2. Accounts Receivable
  3. Accounts Payable
  4. Fixed Assets
  5. Inventory

The SAF-T D406 file to be submitted on a quarterly/monthly basis does not include information on Fixed Assets or Inventory. That data will be part of separate SAF-T files with different filling frequencies, namely the D406 Assets and the D406 Stocks.

Non-resident and small taxpayers will be required to submit a simplified SAF-T file from 2025 that will only account for the purchases and sales carried out through their Romanian VAT ID.

When to submit a SAF-T declaration in Romania

Submission deadlines for SAF-T in Romania can be monthly/quarterly, annual or on demand by the tax authorities.

Monthly or quarterly: The D406 file, except for the ‘Assets’ and ‘Stocks’ sections, shall be submitted monthly or quarterly by resident taxpayers, depending on the applicable VAT regime. The deadline for submission is the last calendar day of the month following the end of the reporting period.

Annual: The ‘Assets’ section can be submitted autonomously and must be filled annually by resident taxpayers within the deadline for submitting the annual financial statements.

On request: The ‘Stocks’ section shall be submitted only if requested by the tax authorities within the deadline established by that request, which cannot be shorter than 30 days.

Timeline of SAF-T in Romania

Romania’s implementation of SAF-T began on 1 January 2022 but only for a specific category of taxpayers. The following dates are when the SAF-T obligation applies to different types of taxpayers:

  • September 2021: Voluntary test period began
  • 1 January 2022: Large taxpayers included in the tax authority’s list from 2021 must file SAF-T
  • 1 July 2022: Large taxpayers who were not in this category on 1 January 2022 must file SAF-T
  • 1 January 2023: Medium-sized taxpayers, financial institutions and insurance firms categorised as large taxpayers must file SAF-T
  • 1 January 2025: Small taxpayers and non-resident taxpayers registered for VAT in Romania must file SAF-T

Understanding SAF-T D406 in Romania

The SAF-T D406 statement is required to be submitted each month or quarter to the Romanian tax authority (ANAF). The submission frequency is dependent on the company’s VAT regime, and it can either be monthly or quarterly.

There is also an annual SAF-T report under D406 – based on the taxpayer’s financial year – which includes asset information from the previous year, as well as a D406 Stock information report which is to be created based on the ANAF’s request.

The SAF-T file must be submitted electronically, through the tax authorities’ public service “Servicii online – Depunere declarații”​.

Implementing SAF-T as a business

Compliance is important for businesses if they are to avoid fines and other penalties from Romania’s tax authorities. To comply with SAF-T, taxpayers must meet reporting deadlines with relevant and complete information – the use of purpose-built solutions can help with this.

Sovos SAF-T solutions can help your organization save time and effort when ensuring compliance with the mandate. Automating the process of preparing files helps not only with efficiency but also accuracy and compliance, providing peace of mind and freeing up valuable time.

For taxpayers established outside of the EU, complying with Romania’s VAT rules requires the appointment of a fiscal representative should they sell in the country. Sovos can help here too – contact us for more information.

Other requirements for VAT compliance in Romania

Tax compliance in Romania goes beyond the SAF-T obligation, especially with Romania’s big push into e-invoicing.

The country introduced an e-invoicing requirement for B2B transactions of high-fiscal risk products in December 2021 and followed that up with an obligation for B2G transactions in May 2022. Both were implemented in July 2022.

Romania is aiming to make e-invoicing mandatory for B2B transactions of all types. Following the EU Council’s derogatory decision, allowing Romania to implement mandatory e-invoicing, Romania published a new B2B mandate with a 2024 oll-out date. The new law also introduces a new reporting system that will operate within the first six months of the introduction of the RO e-Factura e-invoicing system in July 2024. Read more in this overview about e-invoicing in Romania or take a look at this overview about VAT compliance in Romania.

Get in touch with our experts if you need help.

FAQ

SAF-T became mandatory for large resident taxpayers in Romania in January 2022, and for medium-sized resident taxpayers in January 2023. Small and non-resident taxpayers will be obligated under the SAF-T mandate in January 2025.

While SAF-T has a similar reporting format across countries, each country as its own mandatory fields. In Romania, three different declarations are submitted by taxpayers: the general D406 file, the D406 Assets and the D406 Stocks.

SAF-T in Romania currently applies to medium-sized and large resident taxpayers. Small and non-resident taxpayers will need to comply with SAF-T from 2025.

Taxpayers who fail to comply with SAF-T in Romania by not submitting the D406 report may be fined by the tax authority. There is a three-month grace period for non-submission in which no fines will be issued, but after the period a fine of 1,000-5,000 RON may be imposed. For an incorrect or incomplete submission, taxpayers may receive a fine of 500-1,500 RON.

The submission deadline for SAF-T in Romania ends on the last day of the month following the reporting period, which is either a month or a quarter for information outside of stocks and assets.The D406 Assets declaration is to be submitted within the deadline for the yearly submission of the taxpayer’s financial statements.

The D406 Stocks declaration is to be submitted on demand, within the deadline prescribed by the Tax Authorities (a minimum 30-day deadline).

Our Solution capabilities for Romania SAF-T

Data Extraction

Painlessly aggregate and consolidate data from a wide range of source systems across General Ledgers, Accounts Receivable, Accounts Payable (for monthly or quarterly submissions), Fixed Assets (for annual submissions) and Inventory (submitted on demand) complying with Romania’s standard tax control file, D406.

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Data Analytics

Check the accuracy, integrity and quality of complex data structures required by Romania SAF-T to give you peace of mind before you submit your D406 file to be audited by the ANAF.

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File Generation

Ensure that all required data sets from accounting entries, sales and purchase transactions, asset depreciation, stock movements and more, are mapped seamlessly into Romania’s D406 schema, ready to be analyzed and submitted punctually to the ANAF.

More about file generation

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Spain e-invoicing: What you need to know

Spain e-invoicing

Spain is one of many European countries to adopt e-invoicing for taxpayers. With several standards to comply with and additional regional VAT compliance, understanding Spain’s e-invoicing requirements can be complex.

Our regulatory experts break down what you need to know, from specific B2B and B2G standards to required formats. Bookmark this page to stay up to date with the latest e-invoicing requirements in Spain.

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Contents

Who must use e-invoicing in Spain?

Electronic invoicing in Spain has been mandatory for all transactions between public administrations and their suppliers since 2015.

Businesses are under varying e-invoicing obligations depending on the nature of their transactions. Electronic invoices will soon be mandated for business-to-business (B2B) transactions, whereas business-to-government (B2G) transactions may already qualify for e-invoicing. More information on the specifics of a company’s compliance obligations can be found below.

How does e-invoicing in Spain work?

From an e-invoicing perspective, Spain is a post-audit country. There is not an e-invoice clearance requirement, but Spain has been an early adopter of the CTC method in the EU with the introduction of mandatory near real-time invoice data reporting.

Currently, Spain’s tax authority is transitioning to adopt a mandatory B2B e-invoicing requirement that will significantly affect the country’s e-invoicing process.

Spain B2B E-invoicing

Spain originally planned to launch its B2B e-invoicing mandate in July 2024 but postponed it. As the Spanish government commits to giving a year’s notice before implementing a passed law, businesses can currently expect a 2025 launch for the mandate.

The country is expected to implement B2B e-invoicing in a phased approach, with it initially affecting large taxpayers and all other taxpayers joining them a year later.

Read more on Spain B2B e-invoicing.

Spain B2G e-invoicing

Since 2015, e-invoicing has been mandatory in Spain in the public sector. Law 25/2013 mandates that all invoices sent to public sector entities must be sent electronically and signed with an eSignature. All public entities receive invoices through one common point of entry, namely FACe.

An exception to the rule allows paper invoices to be sent to public administrations if the transaction amount is under 5,000 euros.

Timeline for e-invoicing requirements in Spain

The mandatory B2B electronic invoicing requirement will be effective according to the annual turnover of the taxpayer:

  • Entrepreneurs and professionals whose annual turnover exceeds €8 million will have one year after the regulatory framework is approved
  • For the rest of the entrepreneurs and professionals, the electronic invoicing obligation will take effect two years after the regulatory framework is approved

This timeline will be updated when official implementation dates are announced.

What is the required format for an e-invoice in Spain?

Spain’s approved e-invoicing format for B2G transactions is FacturaE and it follows the XAdES standard and uses XML signatures. The central platform to send e-invoices to public administrations is FACe, though business transactions are to be processed through web service FACeB2B.

E-invoices in Spain must comply with EN 16931 and are required to include set information, including:

  • QR code
  • VAT number
  • Date and time
  • Invoice number
  • Total invoice amount including taxes
  • Unique identification number (Número de Identificación Fiscal or NIF)

The e-invoice issuer must archive the electronic document for a minimum of six years.

Standards and communications for e-invoicing in Spain

There are several e-invoicing standards in play in Spain, governing how the process is carried out by taxpayers.

The format of e-invoices for B2G transactions must meet set standards, for example. Namely, electronic invoices must follow the FacturaE format – an XML-based national standard that is used in tandem with a secure eSignature which follows the XAdES standard.

Once e-invoicing for B2B transactions comes into effect, the format of e-invoices must comply with the EN 16931 standard. The following will be accepted:

  • EDIFACT invoice messages compliant with ISO 0735
  • UBL Invoice and Credit note messages in accordance with ISO/IEC 19845:2015

In terms of communication for e-invoicing in Spain, FACe is the singular hub for submitting electronic invoices in B2G supplies.

How Sovos can help

By now, you will be fully aware that tax compliance in Spain isn’t simple for many businesses. You don’t have to do things alone, though – Sovos can help, combining local tax expertise with complete compliance solutions.

Speak with a member of our team today to free yourself up and focus on what truly matters: your business.

Would you like to learn more about e-invoicing compliance in general? Our dedicated guide for e-invoicing can help you.

VAT Compliance in Spain for Businesses

Spain VAT compliance is dense, but it doesn’t have to be hard to achieve. Spanish VAT legislation has been amended numerous times since it was introduced, and there are other regulations organisations need to be aware of too – from SII to e-invoicing.

This is your hub for all things VAT compliance in Spain, covering all mandates and requirements that may apply to your business. Use this page to gain an in-depth understanding of Spanish VAT rules and regulations and how to comply.

VAT rules in Spain

Spain is a complex country for VAT rules, with many elements that companies need to be aware of. These include:

IPT in Spain

Requirements to register for VAT in Spain

Prior to July 2021, foreign sellers were required to be VAT registered if their annual imports into Spain exceeded 35,000 euros. From that date, as per an EU-wide ruling, the threshold was lowered to 10,000 euros. If a company’s annual turnover exceeds that amount, it is liable for VAT in all EU Member States.

Companies that supply goods or services that are subject to VAT in Spain must apply for a domestic VAT ID with their local Administración de la Agencia Estatal de Administración Tributaria (AEAT) branch and appoint a Spanish fiscal representative to communicate with the Spanish tax office on their behalf.

Sovos’ team of experts are specially equipped to handle VAT registration for businesses. Contact us today for further information.

When does VAT liability apply?

In Spain, VAT liability applies to the following types of transactions:

  • Supply of goods or services that takes place in Spain, made by a taxable person
  • Specific intra-community acquisitions (both arrivals and dispatches)
  • Domestic reverse charge
  • Importation

Invoicing requirements in Spain

Spain has strict requirements for the creation, processing and storage of invoices. Invoices must be issued by the 16th of the month following the supply for taxable customers and at the time of the supply for non-taxable customers.

Legislation in Spain declares invoices must include basic details such as:

  • Supplier details
  • Customer details
  • Date of issuance (and date of transaction if they differ)
  • Full description of the goods or services
  • Amount chargeable for goods or services
  • Net taxable supply value
  • Gross amount of the invoice
  • Applied VAT rate(s) and VAT amount per rate

The Spanish government has published a draft regulation with the framework for implementing mandatory B2B e-invoicing. As it is still a draft, taxpayers can expect changes before publication of the final version.

Read our dedicated blog for more information on Spain B2B e-invoicing

Registration for OSS

The EU established the One Stop Shop (OSS) in July 2021, implementing an EU-wide VAT threshold of 10,000 euros and making cross-border online sales in the region simpler. This is part of the EU VAT e-commerce package.

Those registering for the scheme are required to provide specific information to the Member State of identification, and Member states are free to choose how they collect such information electronically.

In addition to OSS, businesses trading in Spain and other EU Member States need to comply with Intrastat. There are country-specific Intrastat thresholds that, once exceeded, require registration and returns for compliance. This system is in place to collect information and produce statistics on the movement of goods between EU Member States.

FAQ VAT compliance Spain

The VAT law in Spain is known as LIVA and has been amended several times so it aligns with EU VAT legislation. Spain does not have a VAT registration threshold, meaning both resident and non-resident taxpayers must register for VAT in the country before they provide taxable supplies.

Typical required information on VAT invoices in Spain include the date of issuance and transaction, supplier’s VAT number, description of goods or services, net value of supply, VAT rate(s) applied and addresses of both the supplier and customer.

The standard VAT rate in Spain is 21%. That said, the country also has zero-rated goods which must be reported on VAT returns – even though no VAT will be charged on the products.

Spain has a reduced VAT rate of 10% for health products, hotels, restaurants, and sports and entertainment activities, and 4% for certain food items, books, magazines and newspapers.

Spain does not have a VAT registration threshold, meaning both resident and non-resident taxpayers must register for VAT in the country before they provide taxable supplies.

How Sovos can help

It should be clear now that VAT compliance in Spain can be a tall, complex task. Future-proof your compliance with Sovos, a single vendor with both global and local tax expertise. 

Contact our expert team today so you can concentrate on growing your business without compliance concerns.

Important verifications beyond TIN matching

TIN matching typically occurs at two points when paying a vendor or customer: when onboarding a new vendor or customer based on information collected on Form W9 and prior to reporting amounts paid on 1099s to ensure name/TIN information is still accurate. When it comes to onboarding new vendors or customers, there are two additional verifications beyond TIN matching businesses must be aware of. Understanding these verifications can help prevent your organization from working with fraudulent individuals or businesses.

Read more about verifications beyond TIN matching.

Japan's Tax System

Japan's Tax System

Starting with the introduction of a multiple tax rate system in 2019, Japan is in the middle of a multi-year process of upgrading its consumption tax system. Through this significant change, the Japanese government seeks to solve a tax leakage problem that has existed for years.

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Japan's tax reforms

The recent series of tax reforms in Japan started with the introduction of its multiple tax rate system on 1 October 2019. Following this, changes in the country’s indirect tax, the Japanese Consumption Tax (JCT), started to take place. To counter systemic problems caused by the current ledger system structure, anew system – the Qualified Invoice System –will be introduced from 1 October 2023. The key difference from the current system is that a Qualified Invoice must include a breakdown of applicable tax rates for that given transaction.

Not long after these changes were announced, a new organisation, the E-Invoice Promotion Association (EIPA), was established in July 2020. It aims to promote digitization of overall commercial transactions. Leveraging the opportunity presented by the new Qualified Invoice System, the EIPA began to work on developing a standard specification for electronic invoices.

Since January 2021, the EIPA – with support from the Japanese government – has been working with the OpenPEPPOL team to develop a Japanese specification that meets the country’s regulatory framework and business demands. In September 2021, Japan acquired PEPPOL Authority status and aims to allow businesses to issue and receive electronic invoices through PEPPOL in the Autumn of 2022.

Japan's tax system quick facts

  • Under the new system, only registered JCT payers can issue qualified tax invoices. On the buyer side, taxpayers will only be eligible to input tax credit where a qualified invoice has been issued
  • Taxpayers must register with Japan’s National Tax Agency (NTA) to issue qualified invoices. Registration began in October 2021 and must be completed before 31 March 2023
  • Invoices must be archived according to Italian-style storage requirements: to be compliant, taxpayers must either timestamp their invoices or draw up a Storage and Maintenance Guideline describing how the invoices are archived and how this meets applicable requirements
  • Invoices should be stored in such a way to guarantee the integrity, authenticity and availability during the storage period
  • Foreign storage is allowed provided it fulfills the requirement for storage under Japanese law
  • Outsourcing of invoice issuance is allowed with no restrictions or requirements

Japan's mandate rollout dates

  • 1 October 2019 – Japan introduces its multiple tax rate system
  • 14 September 2021 – the Japanese Digital Agency obtained PEPPOL Authority status
  • 1 October 2022 –EIPA aims to enable businesses in Japan to issue and receive electronic invoices through PEPPOL
  • 31 March 2023 – Latest date to apply for registration with the NTA to issue qualified invoices
  • 1 October 2023 – Qualified Invoice System will be introduced

Quick facts about Japan's Consumption Tax

Introduced in January 1989, it’s the indirect tax charged on the consumption of goods and services in Japan. There are national and regional levies, and a reduced rate of Consumption Tax in Japan.

Japan’s Consumption Tax is the equivalent of VAT which is charged across the European Union.

Consumption Tax in Japan is levied when a business transfers goods, provides services or imports goods into Japan.

A refund of Consumption Tax in Japan isn’t possible for businesses without taxable sales in the country.

How Sovos can help

As Japan implements its Consumption Tax System updates, requirements for Japanese taxpayers will change. Need help ensuring your business stays compliant with all future Japanese Consumption Tax system updates?

Our experts continually monitor, interpret and codify regulatory changes from around the world into our software, reducing the compliance burden on your tax and IT teams.

Serbia E-invoicing

Serbia is in the process of introducing mandatory e-invoicing for all taxpayers

Following other Eastern European countries such as Poland and Romania, Serbia is on its way to implementing the mandatory e-invoicing system for the B2B (business to business) and B2G (business to government) sectors.

The Law on Electronic Invoicing that came into force in May 2021, introduces the clearance e-invoicing system and presents the centralised continuous transaction controls (CTCs) platform called SEF (Sistem E‑Faktura) for sending, receiving, capturing, processing and storing structured electronic invoices. Additionally, there is a system to help taxpayers with the processing and storage of invoices called the Sistem za Upravljanje Fakturama (SUF).

The new legislation aims to replace paper invoices with electronic invoices and outlines the requirements for the issuance of e-invoices in B2B and B2G transactions.

Have questions? Get in touch with a Sovos Serbia VAT expert.

Scope of e-invoicing mandate

Under the new e-invoicing framework, e-invoices must be sent and received in accordance with Serbian e‑invoicing standards (custom application of the standard EN 16931-1). All e‑invoices must be submitted via a centralised platform to the recipient who must accept or reject the invoice.

  • For invoices relating to B2G transactions: 15 days to accept an invoice, in the case of no response the invoice will be deemed accepted.
  • For invoices relating to B2B transactions: This requirements will come into force in 2023. After 15 days a re-notification is sent, if the buyer does not accept or reject the electronic invoice within five days from the date of re-notification that the electronic invoice has been issued, the electronic invoice shall be deemed rejected

Currently in scope are resident taxpayers in the private and public sector and non-resident businesses with a local fiscal representative in Serbia.

Quick facts

  • Serbian e-invoices must be issued in an XML format and comply with UBL 2.1 Standard
  • Taxpayers must register first via the eID.gov.rs portal to start using the SEF platform, by using either:
    • Qualified Electronic Certificate or
    • Parameters for two-factor authentication
  • Invoices must be sent and received to EN 16931‑1 standard
  • The Ministry of Finance needs to give consent to the service provider, who needs to be registered in Serbia, to provide e-invoicing and archiving
  • Issuing electronic invoices through SEF ensures the integrity and authenticity of the electronic invoice

Mandate rollout dates

May 2021: Law on Electronic Invoicing entered into force

1 May 2022: All suppliers in the public sector must send invoices electronically and the Serbian government must be able to receive and store them. (G2G/B2G)​

1 July 2022: Serbian public entities are obliged to send e‑invoices to companies, who must be able to receive and process them. (G2B)​

1 January 2023: E‑invoicing will be extended to the entire B2B sector. (B2B)​

How can Sovos help?

Need help to ensure your business stays compliant with the emerging mandatory e‑invoicing for all taxpayers in Serbia?

Our experts continually monitor, interpret and codify legal changes into our software, reducing the compliance burden on your tax and IT teams.

Learn how Sovos’ solution to address the changing VAT compliance requirements in Serbia can help companies stay compliant.

Indonesia’s VAT requirements

Indonesia’s e-invoicing system and continuous transaction controls

After experiencing challenges in its tax control system, Indonesia adopted an e‑invoicing system, locally known as e‑Faktur. Leveraging data reported in real-time via continuous transaction controls (CTCs) allows the Indonesian tax authorities to reduce occurrences of fraud whilst helping to close the tax gap.

Have questions? Get in touch with a Sovos Indonesia CTC expert.

CTC reforms

Introduced in 2014 and effective from 2016, Indonesia’s e‑invoicing system seeks to combat the tax gap. Indonesia’s solution was the implementation of an invoice clearance system, where invoices must be approved by the local tax authority prior to being sent to a customer.

Quick facts

  • E-invoicing has been mandatory for all corporate VAT taxpayers since July 2016.
  • E-invoices (e-Faktur Pajak or e-FP) should be created by applications and systems prescribed by the Director of Taxation (DGT). These include client desktop, web-based and host-to-host applications.
  • Electronic signatures are required for the issuance of e-invoices.
  • It’s compulsory for all invoices to be processed and issued electronically via the government hosted eFaktur platform. The submission platform for the VAT return has been integrated with the e-invoicing platform.
  • Electronic certificates are required to verify taxpayer identity and are valid for two years.
  • Activation code and password are required for access to e-Nofa to request electronic tax invoice serial numbers.
  • Using e-Faktur, VAT returns are periodically submitted (typically monthly).

Mandate rollout dates

2014 – e-Faktur Pajak introduced

2016 – e-Faktur Pajak became effective

1 October 2020 – New e-Faktur Pajak version 3.0 released

How can Sovos help?

Need help to ensure your business stays compliant with the e-invoicing obligations in Indonesia?

Our experts continually monitor, interpret and codify changes into our software, reducing the compliance burden on your tax and IT teams.

Learn how Sovos’ solution for VAT compliance changes can help companies stay compliant in Indonesia and around the world.

Israel e-invoicing

Israel is set to implement a continuous transaction controls (CTC) model that will require businesses to submit invoice data in electronic format for the tax authority to validate.

The mandate, set to come into force in May 2024, will require invoice data to be validated by the country’s tax authority before being sent to the final recipient. Read on for an overview of Israel e-invoicing requirements – we encourage you to bookmark the page to stay updated as the mandate develops.

At a glance: Characteristics of invoicing data submission in Israel

CTC Type 
CTC Clearance

Format 
JSON

Allocation Number 
Assigned by the ITA

 

E-invoicing 
Not mandatory

Electronic Signature 
Not applicable (though needed in case of e-invoicing)

Archiving 
Not applicable

Electronic invoicing laws in Israel

From 5 May 2024, Israel will make clearance CTC clearance mandatory. Authorised dealers (taxpayers) will have to clear invoices above a threshold of NIS 25,000 (before VAT), obtaining an allocation number acquired by the SHAAM – a computer system provided by the Israeli Tax Authority (ITA).

The invoice value threshold will be gradually reduced annually until 2028, ending at NIS 5,000 pre-VAT. Nevertheless, suppliers may report invoice data to the tax authority for clearance and request an allocation number for any amount.

Besides CTC clearance, e-invoicing rules remain in place and do not change with the new CTC requirements. Electronic invoices are still optional.

Since 2019, public entities in Poland have been mandated to receive and process e-invoices. While currently optional for suppliers of public entities, the transmission of e-invoices will be required for B2G and B2B transactions when the mandate is implemented (this was planned for 1 July 2024 until it was postponed in January 2024).

CTC clearance model

Israel’s model will include a clearance system from 5 May 2024. Businesses that exceed a specific threshold will be required to obtain an allocation number for invoices regarding B2B transactions. They can do so by issuing the invoice to the tax authority before sending it to the final customer.

Without receiving this number and including it on invoices, businesses will not be able to deduct input VAT.

Israel B2B e-invoicing

Israeli CTC clearance covers B2B transactions between authorised dealers.

However, e-invoicing is not mandatory under the new CTC clearance system. In case invoices are issued in electronic format (structured or unstructured format, including PDF), they must be cleared by the ITA and assigned with an allocation number before exchanged with the trading party.

Without receiving this number and including it on invoices, businesses will not be able to deduct input VAT.

Benefits of using e-invoicing in Israel

Although CTC Clearance mandate does not require e-invoicing, there are numerous benefits for businesses that electronically issue and receive invoices, including:

  • Cost savings through the reduction of paper, postage and manual labour
  • Saving time by using automated and structured processes
  • Streamlining operations through interoperable, uniformed initiatives and systems
  • Fewer issues and risks through the validation and authentication of data

Timeline of e-invoicing clearance in Israel

While combating fraudulent invoices has been discussed in Israel for a long time, the implementation of the upcoming CTC model is a relatively recent development.

  • February 2023: The 2023-2024 state budget and economic plan are approved, outlining a clearance CTC model
  • June 2023: The ITA announces plan for CTC implementation
  • July 2023: The ITA publishes technical specifications for the upcoming CTC model
  • October 2023: Clearance model is postponed from 1 January 2024
  • 1 January 2024: The original date that the clearance e-invoicing model would be implemented
  • 1 January 2024: The ITA platform becomes operational
  • 5 May 2024: CTC clearance comes into effect
  • January 2025: Invoice threshold lowers to NIS 20,000 pre-VAT
  • January 2026: Invoice threshold lowers to NIS 15,000 pre-VAT
  • January 2027: Invoice threshold lowers to NIS 10,000 pre-VAT
  • January 2028: Invoice threshold lowers to NIS 5,000 pre-VAT

What is the future of e-invoicing in Israel?

While electronic invoice data will be required as part of the CTC initiative, Israel does not yet have a specific electronic invoicing mandate requiring dealers to issue invoices electronically.

Currently, Israel’s e-invoicing rules – which are classified as post-audit – include e-signing, content remarks and prior notification to the tax authority.

Israel has the potential to go the way of countries like Romania and Spain, mandating the use of e-invoices across transactions with governments and businesses. There is no official word on Israel’s future e-invoicing plans beyond the current CTC mandate.

What happens if I don’t comply?

If an allocation number is not requested for the invoice by the supplier, the buyer cannot deduct its VAT based on that invoice.

Setting up e-invoicing in Israel with Sovos

Sovos’ continuous transaction controls (CTC) software was purpose-built to help customers stay on top of their obligations wherever they do business, even as the rules change.

Currently, e-invoicing is permitted in Israel, provided it is prominently stated on the invoice that it is a ‘computerized document’ and prior notification is made to the ITA. A digital signature compliant with the local law is required to ensure the integrity and authenticity of the electronic invoice.

Storage of e-invoices must be within Israel – unless derogation has been granted. Both issuance and storage of e-invoices can be outsourced to third parties like Sovos.

Taxpayers opting to use e-invoices must comply with the abovementioned rules, as well as the CTC clearance requirements rolling out in 2024.

As CTCs and e-invoicing continue to grow in global adoption, it is vital to partner with a provider that closely monitors the decisions of tax administrations and understands the regulations you face. Sovos can help to stay compliant wherever you do business.

Get in touch today.

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Israel CTC Clearance and E-invoicing FAQ

No, e-invoicing is not mandatory in Israel. Israel’s continuous transaction controls (CTC) mandate involves the electronic submission of invoice data and is set to come into effect on 5 May 2024.

Electronic invoice data must include specific information when submitted to the tax authority, including invoice ID, VAT number, invoice date, invoice amount and accounting software number. They also need to be given an allocation number by the ITA for the buyer to use this invoice for a tax deduction, as per the CTC clearance mandate.

Sovos has the first global solution for e-invoicing compliance, including e-reporting functionality.

Within the CTC mandate, the use of emergency allocation numbers is instituted as a contingency measure to address potential failures in its computer systems. In anticipation of such events, taxpayers must acquire and store these emergency numbers.

In case the taxpayer chooses e-invoicing, electronic invoices in Israel must be signed with a digital signature compliant with the local law.

Israel’s mandated CTC clearance platform requires electronic invoice data to be submitted to and approved by the Israeli Tax Authority in real time. The authority will assign an allocation number and verify or reject the invoice data. Once validated, the allocation number will be returned to the seller so it can be issued to the buyer (in electronic or paper format).

Lithuania’s VAT Requirements

Lithuania’s SAF-T Mandates Framework

Seeking to modernise and digitize its tax systems, the Lithuanian Customs Office of the State Tax Inspectorate announced sweeping changes to its tax system in 2016 with the introduction of the Standard Audit File for Tax (SAF‑T) and the launch of its online portal, eSaskaita.

Have questions? Get in touch with a Sovos Lithuania SAF-T mandates expert.

SAF-T mandates

SAF-T mandates

Implemented with a phased approach, Lithuania’s SAF‑T mandate became mandatory for all taxpayers in 2020. Whilst there is no periodic SAF‑T reporting, businesses must maintain records for the tax authorities in the event they are requested.

Quick facts on SAF-T mandates

  • E-invoices must be accepted provided its integrity and authenticity can be guaranteed from the point of issuance until the end of the storage period.
  • If an invoice is in electronic form, data ensuring its integrity and authenticity must be stored by electronic means.
  • Suppliers may submit documentation by:
    • Using any certified PEPPOL Access Point with an AS4 Profile
    • Manually keying in the invoice information via an online portal
    • Uploading files in XML format (this requires the economic operator’s accounting system to be suitable for storing e-invoices in this format).
SAF-T mandates
SAF-T mandates
  • Service providers to Lithuanian taxable persons not established in an EU Member State must comply with certain additional requirements regarding the outsourcing of e-invoice issuance.
  • The i.MAS, Lithuania’s “Intelligent Tax Administration System,” comprises three main parts:
    • i.SAF reporting of sales and purchase invoices on a monthly basis
    • i.VAZ reporting of transport/consignment documents
    • i.SAF-T accounting transaction report, which is only required when requested by the tax authority.
  • Full SAF-T files are only submitted upon request of the Lithuanian tax authority.

SAF-T mandates rollout dates

  • 1 Oct 2016 – Requirement to submit data on issued and received VAT invoices began
  • 2016 -2019 – Phased rollout of SAF‑T requirements to Lithuanian businesses dependant on revenue
  • Jan 2020 – All businesses required to comply with SAF‑T mandate
  • 2021 – Management and archiving of documents, including invoices, became a licensed activity and must meet certain requirements for integrity, authenticity, security and management to be certified by the Lithuanian Chief Archivist
SAF-T mandates
INFOGRAPHIC

Lithuania’s SAF-T Requirements

Understand more about Lithuania SAF-T including when to comply, submission deadlines, filing requirements and how Sovos can help.

How can Sovos help with SAF-T mandates and VAT compliance?

Need help to ensure your business stays compliant with the SAF‑T obligations in Lithuania?

Our experts continually monitor, interpret and codify changes into our software, reducing the compliance burden on your tax and IT teams.

Learn how Sovos’ solution for Lithuanian SAF‑T and other VAT compliance changes can help companies stay compliant.

E-Invoicing Thailand: New Approach

New regulations for Thailand's e-tax invoicing solutions and receipts expected soon

Thailand’s current e-invoicing legal framework has been in effect since 2012 and follows a post-audit approach.

The Thai Revenue Department and Electronic Transactions Development Agency (ETDA) are working together to improve and further develop the e-tax invoicing system. As a result, new regulations on e-tax invoicing and receipts are expected in the future.

Get in touch with a Sovos Thailand electronic invoicing expert.

Thailand's E-tax invoicing solutions

From 2017, the Thai Revenue Department issued regulations on electronic tax invoices and receipts. Subject to approval, taxpayers can prepare, deliver and keep their e-tax invoices and receipts in electronic format. Read more about e-tax in Thailand here.

Thailand electronic invoicing: facts

  • E-invoices must be digitally signed using a certificate issued by a certification authority and approved by the Thai Revenue Department.
  • E-invoices must be submitted in XML format to the Revenue Department monthly.
  • Outsourcing of e-invoice issuance is allowed provided the third-party service provider is certified by the Thai Revenue Department.

E-tax invoicing rollout dates

  • 2012 – E-invoicing permitted
  • 2017 – New regulations issued on electronic e-tax and receipts.
  • 2020 – EDTA began a certification process for service providers to assess whether applicants’ solutions are secure and compliant.

How can Sovos help with invoicing solutions?

Need help to ensure your business stays compliant with emerging e-invoicing obligations?

Our experts continually monitor, interpret and codify legal changes and requirements into our software solutions, taking care of your indirect tax compliance so you can focus on your core business.

Learn how Sovos’ solutions for continuous transaction controls and VAT compliance obligations can help companies stay compliant.

Luxembourg VAT Requirements

VAT in Luxembourg

Luxembourg is one of many European countries to implement SAF-T and e-invoicing to provide greater visibility into a wide range of business, accounting and tax data.

Luxembourg introduced SAF-T requirements in 2011. In 2019 the country introduced an e-invoicing legislation.

Luxembourg is part of the EU single market economy and falls under the EU VAT regime. The EU issues VAT Directives laying out the principles of how the VAT regime should be adopted by Member States. These Directives take precedent over any local legislation.

VAT law within the country is administered by the Administration de l’Enregistrement et des Domaines and is contained within the General Tax Code.

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Quick facts

  • Just like in any other EU Member State, e-invoicing is permitted in Luxembourg, subject to the buyer accepting the exchange of electronic invoices.

  • Businesses must ensure integrity of invoice content and authenticity of origin for their invoices.  Integrity and authenticity can be proved using Advanced Electronic Signatures, ‘proper EDI’ with an interchange agreement based on the EC 1994 recommendation, and Business Controls-based Audit Trail.

  • In May 2019, Luxembourg adopted legislation about e-invoicing in public procurement following the EU Directive 2014/55/EU. The Directive states that e-invoices will continue to be exchanged voluntarily by suppliers to the government and the centralised PEPPOL access point will continue to be used.

  • Prior authorisation is required before outsourcing to a service provider – written authorisation is recommended.

  • Invoices stored in electronic form must have evidence of their integrity and authenticity stored electronically as well.

  • E-invoices may only be stored in EU Member States (or other countries) of which Luxembourg has signed a mutual tax assistance treaty – prior to notification and access.

  • VAT returns may be filed monthly, quarterly or annually electronically through Luxembourg’s online platform (eCDF) via PDF or XML format. Alternatively, annual filings can be made either in electronic format through the portal or via sending a paper copy of the VAT return to the requisite tax office.

  • To submit tax returns electronically, taxpayers must ensure the service provider they use is certified within eCDF.

SAF-T reforms

Officially implemented in 2011, Luxembourg’s Standard Audit File for Tax (SAF-T) is locally known as Fichier Audit Informatisé AED (FAIA).

Businesses must, if requested, submit their financial data electronically in a format that is compliant with AED electronic audit file specifications (i.e., in the specified FAIA format). Only resident businesses subject to the Luxembourg Standard Chart of Accounts must file the FAIA.

Mandate rollout dates

2011 – Introduction of SAF-T, known as Fichier Audit Informatisé AED (FAIA)

2019 – Adoption of e-invoicing legislation in public procurement with 2014/55/EU Directive

How can Sovos help?

Need help to ensure your business stays compliant with evolving e-invoicing, reporting and SAF-T obligations in Luxembourg?

Keeping up with VAT compliance obligations has become more difficult as Luxembourg continues to take steps to reduce its VAT gap and modernise the system.

Our experts continually monitor, interpret and codify changes into our software, reducing the compliance burden on your tax and IT teams.

Learn how Sovos’ solutions for changing SAF-T and VAT obligations can help companies stay compliant.

Slovakia VAT Requirements

Slovakia expands continuous transaction controls (CTCs)

The modernization of tax and tax controls remains a high priority for Slovakia’s tax authority. The Slovakian Ministry of Finance plans to introduce a continuous transaction control (CTC) scheme, with the aim to lower Slovakia’s VAT gap to the EU average and obtain real-time information about underlying business transactions.   

The Slovakian tax authorities have begun to introduce mandatory business to government (B2G) and government to government (G2G) e-invoicing via the IS EFA platform. Regarding business to business (B2B) and business to consumer (B2C) e-invoicing, there is currently no indication when the mandate will be rolled out, yet the IS EFA platform is planned to also be used for B2B e-invoicing.

Have questions? Get in touch with a Sovos Slovakia CTC expert.

Quick facts on Slovakia e-invoicing and VAT reporting

e-Invoicing

  • Just like in any other EU Member State, e-invoicing is permitted in Slovakia, subject to the buyer accepting the exchange of electronic invoices.
  • While Slovakia today is considered a post audit jurisdiction, a CTC reform is currently underway.
  • The implementation of the mandatory B2G and G2G schedule for the involvement of government and public administration institutions as well as for their suppliers, is expected to happen progressively throughout 2023 and 2024.
  • E-invoices can be stored in another Member State without notification, provided they are available in Slovakia should they be requested by the tax authority.

VAT Reporting

  • Filed either monthly or quarterly and must be submitted through a downloadable form issued by the Slovakian tax authority.
  • Additionally, Slovakia requires the submission of the Slovak Control Statement.
  • Data submitted to the tax authority must be in XML format.
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Slovakia CTC Requirements

Understand more about Slovakia’s CTC requirements including when businesses need to comply and how Sovos can help.

Slovakia's upcoming CTC reform 2022

The Slovakian tax authorities have begun to slowly introduce mandatory B2G and G2G e-invoicing via the IS EFA platform, but there is currently no indication if/when a business to business (B2B) and business to consumer (B2C) mandatory e-invoicing mandate will be rolled out. The previous government decided to freeze the B2B and B2C element of the CTC mandate, with no clear date when it will be implemented, or if the information outlined in the original draft legislation will be maintained in the future.

According to the unpublished CTC draft law, which has been put on hold by the current government, suppliers would have to report invoice data to the tax authority’s e-invoicing platform, IS EFA, before issuing them to their customer.  Similarly, buyers would have to report data from the received invoice.

Mandated e-invoicing rollout dates

B2G and G2G throughout 2023 and 2024

  • B2B and B2C TBD

How can Sovos help with VAT compliance?

Sovos software already addresses the periodic reporting requirements facing companies with VAT compliance obligations domestically in Slovakia, as well as those with obligations due to trade with counterparties in other EU Member States and third countries.

Building on our existing commitment to Slovakia and pending the release of official information and detailed specifications, we’re planning further development to our core CTC platform to ensure our customers remain continually compliant with Slovakian CTC regulations, in line with the emerging digitization of tax controls in Slovakia.

Learn how Sovos’ solution for VAT compliance changes can help companies stay compliant.

Philippines VAT Requirements

VAT in the Philippines

There have been improvements in recent years to VAT revenue collection in the Philippines, but there are a considerable number of exemptions from the country’s 12% VAT rate.

After receiving funding from South Korea to investigate and adopt a CTC e-invoicing regime, the Philippines is expected to roll out a phased VAT control reform over the coming years.

Get the information you need

CTC reforms

In 2018, the Philippines launched the Tax Reform for Acceleration and Inclusion (TRAIN), which included several tax reform proposals.

The TRAIN proposals included the requirement for large taxable persons who were engaged in e-commerce or export to issue e-invoices, e-receipts and to report sales data to the country’s tax administration, the Bureau of Internal Revenue (BIR).

Quick facts

  • In July 2022, the Department of Finance (DOF) intends to launch a CTC e-reporting system pilot program covering B2B invoicing and B2C receipts per the TRAIN law mandate. By this date, the 100 largest taxpayers in the country must be live with the system.
  • E-invoice data must be reported in JSON format and contain the issuer’s electronic signature.
  • All e-invoice data and e-receipts must be transmitted to the tax authority’s invoice system (EIS) either immediately after issuance or in a batch submission once per day (near real-time).
  • E-invoice data reporting and e-receipt reporting can be done either through dedicated APIs or through the BIR’s web portal.
  • Suppliers can deliver invoices to customers electronically via email in PDF format or as a hard copy.
  • E-invoices must be archived for 10 years.

Mandate rollout dates

2018 – TRAIN law was introduced.

End of January 2022 – Pilot program environment was made available to eligible taxpayers to establish test connectivity and verify file formats.

April 2022 – Six pilot companies will test the system end-to-end by transmitting e-invoices to the EIS.

July 2022 – 100 pilot taxpayers, including the initial six will have to report all their invoicing data to the EIS through the new system.

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Philippines CTC Requirements

Understand more about Philippines’ continuous transaction controls including when businesses need to comply, and how Sovos can help.

How can Sovos help?

Do you need help ensuring your business stays compliant with the upcoming e-invoicing obligations in the Philippines?

Sovos already provides early adopters with a solution connected to the Philippines Tax Authority Platform and helps other taxpayers prepare for the extended rollout of the CTC e-reporting system.

Learn how Sovos’ solution for VAT compliance changes in the Philippines can help your business stay compliant.