The Inland Revenue Authority of Singapore (IRAS) has announced the implementation of a phased adoption of InvoiceNow, the national e-invoicing framework based on the Peppol network, for GST registered businesses starting voluntarily in May 2025. The mandate will cover B2B transactions only, as the government is expected to make B2G mandatory in the coming years.

What is InvoiceNow?

InvoiceNow is a nationwide e-invoicing initiative by The Infocomm Media Development Authority (IMDA) for SMEs and large enterprises to streamline their invoicing for a faster and more sustainable way to transact, nationwide and worldwide.

What’s the timeline?

Singapore’s nationwide e-invoicing network was first announced in 2019 and has recently been referred to as InvoiceNow. The mandate will require GST registered businesses to use InvoiceNow solutions to transmit invoice data to IRAS. The transmission of invoice data to IRAS will be done through Peppol Access Point (AP) service providers, extending the traditional four corner e-delivery model to a fifth corner model.

The mandate will be implemented in phases, as follows:

Even though an implementation timeline for all businesses has not been shared yet, further updates are expected in the future.

Sovos is here to help

Saphety Level – Trusted Services, S.A is an IMDA-certified Peppol service provider in Singapore. Our regulatory experts can connect to the InvoiceNow network on your behalf.

e-invoicing in Germany

Germany, like many European countries, is on its way to implementing electronic invoicing requirements for domestic taxpayers of all shapes and sizes. However, e-invoicing is yet to be fully implemented and mandated in the country.

E-invoicing in Germany is currently divided by transaction type. There are national and federal requirements for B2G transactions, but the time hasn’t come for B2B transactions to utilise e-invoices yet. This will begin to change in 2025, and by 2028, all German businesses will be mandated to send and receive invoices electronically.

With Germany’s e-invoicing rollout fragmented and intensive to follow, use this page as your go-to overview to ensure you meet your obligations. Bookmark this page and revisit it whenever you need a reminder of the current requirements.

Table of contents

At a glance: Germany e-invoicing

Germany B2B e-invoicing

CTC Type

  • Post Audit

Network

  • N/A

Format

  • Compliant with EN 16931

eSignature Requirement

  • Not mandatory, qualified e-signature can be used

Archiving Requirement

  • 10 years

Germany B2G e-invoicing

CTC Type

  • Decentralised/PEPPOL

Network

  • Individual state platforms

Format

  • Xrechnung & PEPPOL BIS

eSignature Requirement

  • N/A

Archiving Requirement

  • 10 years

E-invoicing regulations in Germany

Germany B2B e-invoicing

From January 2025, taxpayers must be able to receive electronic invoices. Sending and receiving e-invoices will become mandatory in Germany from 1 January 2027, applying to companies with an annual turnover exceeding EUR 800,000. From January 2028, it will apply to all companies.

This go-live date for German B2B e-invoicing was set in March 2024 when the Bundesrat passed the law known as ‘Wachstumschancengesetz’.

Germany B2G e-invoicing

E-invoicing is mandated when trading with public administrations, though it’s divided at a federal state level. There is a national mandate, but it runs alongside its 16 federal states – each of which has legislative freedom to develop its own e-invoicing platform.

The following German federal states have implemented e-invoicing for governmental transactions:

  • Baden-Württemberg
  • Bavaria
  • Berlin
  • Bremen
  • Hamburg
  • Hessen
  • Lower Saxony
  • Mecklenburg-Vorpommern
  • North Rhine-Westphalia
  • Rhineland-Palatinate
  • Saarland
  • Saxony
  • Saxony-Anhalt
  • Schleswig-Holstein
  • Thuringia

The aforementioned European Directive (2014/55/EU) requires member-state government entities to be able to receive and handle electronic invoices according to the CEN standard, EN 16931.

Timeline: e-invoicing adoption in Germany

The implementation of e-invoicing in Germany can be hard to follow. Here are the main dates you need to know:

  • April 2017: Germany publishes its e-Bill law
  • 18 April 2020: Federal states implement mandatory e-invoicing in public procurement
  • 27 November 2020: Public authorities must receive e-invoices from state authorities
  • July 2023: Germany’s Federal Ministry of Finance presents draft legislation for mandatory e-invoicing
  • 22 March 2024: Germany’s Federal Council approves a legislative package that includes the introduction of mandatory e-invoicing
  • 1 January 2025: German taxpayers must be able to receive e-invoices from their suppliers (B2B)
  • 1 January 2027: German taxpayers with an annual turnover of at least EUR 800,000 must issue e-invoices for B2B transactions
  • 1 January 2028: Remaining German taxpayers must issue e-invoices for B2B transactions

Benefits of e-invoicing in Germany

Implementing electronic invoicing can benefit taxpayers by automating processes. Not only can this save time and headspace, it can also significantly reduce the risk of errors by removing the need for people to input and handle data manually.

Future of e-invoicing in Germany

While it’s now clear that there’s more to come on the e-invoicing front in Germany, there’s a larger initiative that could shift how the technology is implemented in the country – and across EU Member States at large.

VAT in the Digital Age is a proposal to digitize the European VAT system, implementing digital reporting and e-invoicing, among other new, innovative tax solutions.

It’s worth noting that while Germany is still working on implementing e-invoicing for all resident taxpayers, many countries are further along in their electronic invoicing journey. Global tax compliance can be tough, considering the nuances of each country’s tax digitization journey, but Sovos can help – wherever you do business.

Additional obligations for VAT compliance in Germany

While electronic invoicing is an important component of tax compliance in Germany, organisations have other obligations to stay on top of.

Staying updated with regulatory expectations becomes even more complicated when you consider the evolving nature of laws. Not only do you need to meet your current obligations, but you also need to stay on top of what’s to come – this is demanding in terms of both time and resources.

Non-compliance can be costly, but you don’t need to fall behind. Find out more about German VAT compliance with our dedicated overview.

FAQ

B2G e-invoicing is mandatory in Germany, and B2B e-invoicing is currently scheduled to come into effect from 1 January 2027 for companies with an annual turnover exceeding EUR 800,000.

For B2G and B2B e-invoicing, German legislation requires the secure archival and access of electronic invoices for 10 years.

Germany has laid out plans to make B2B e-invoicing mandatory for resident taxpayers, following this timeline:

  • 1 January 2025: Taxpayers must be able to receive e-invoices
  • 1 January 2027: Taxpayers with an annual turnover exceeding EUR 800,000 must use e-invoices
  • 1 January 2028: All taxpayers must use e-invoices.

The ZRE stands for Zentrale Rechnungseingangsplattform des Bundes, which translates as Central Invoice Submission Portal. ZRE is a web portal that allows suppliers and service providers to send electronic invoices to federal entities.

ZUGFeRD is a hybrid e-invoicing format that includes human-readable (PDF/A-3) and machine-interpretable invoice data. It’s based on XML, allowing invoices to be sent as attachments or embedded within an email.

ZUGFeRD meets the requirements of the European standard (EN 16931).

XRechnung is a standard for electronic invoicing that the German government accepted in late 2020. It was devised as a standard for converting invoice information into an XML data file, serving as an e-invoice.

XRechnung also meets the requirements of the European standard (EN 16931).

B2G e-invoicing has been mandated at a national level since mid-2019, meaning that all Member State government agencies must be able to receive and manage electronic invoices.

Elsewhere, here’s the timeline for B2B e-invoicing in the country:

  • From January 2025, all German taxpayers must be able to receive electronic invoices from their suppliers.
  • From January 2027, all German taxpayers with an annual turnover of over EUR 800,000 must issue electronic invoices.
  • From January 2028, all German taxpayers must issue and receive electronic invoices.

When transacting with federal contracting authorities, you should send an electronic invoice through the relevant state’s individual transmission platform.

Setting up e-invoicing in Germany with Sovos

B2B e-invoicing has yet to be implemented in Germany, but it provides yet another obligation for organisations to meet once it is. Then, consider the other countries where you do business and the stages they may be at in their tax digitization journeys.

One solution is to pay attention to evolving mandates and regulations everywhere you operate. The more freeing solution is to appoint a single tax compliance partner, like Sovos, to do the busy work for you.

Trusted by the world’s best companies, including half the Fortune 500, Sovos’ solutions provide global compliance through local expertise.

Get in touch with us

VAT Compliance in Germany: An Overview for Businesses

Tax compliance in Germany is fragmentary by nature and requires resources to ensure compliance. Consider that compliance for many German taxpayers requires meeting several mandates, and the fact that such regulations are updated often, and you understand the challenge taxpayers have to undertake. From VAT to IPT, multiple moving parts demand precious time and resources.

This page is your overview of all tax compliance obligations across Germany. To keep up with evolving requirements, be sure to bookmark and revisit frequently.

Germany: General VAT information

Germany VAT compliance can be resource-heavy to stay on top of due to the many requirements imposed on taxpayers. These include:

Periodic VAT return Monthly
10th day of the month following the end of the tax period

Quarterly
10th day of the month following the end of the tax period
Annual VAT Return Annual
31st May of the year following the reporting year
EU Sales and Purchases List Monthly
25th day of the month following the end of the tax period (for goods once sales pass EUR 100,000 annually)

Quarterly

25th day of the month following the end of the tax period (for services and goods when sales are under EUR 100,000 annually)
Intrastat Monthly
10th day of the month following the relevant month
VAT rates 19%
7%
0% and Exempt
Intrastat thresholds Arrivals: EUR 800,000
Dispatches: EUR 500,000

VAT Rules in Germany

Germany e-invoicing

E-invoicing is on its way for all taxpayers in Germany, but complete coverage is not here just yet.

Electronic invoicing is currently divided by transaction type. While there are national and federal requirements for B2G transactions, electronic B2B invoices are still not mandated.

Taxpayers may find Germany’s e-invoicing scheme complicated due to its fragmented status, and the fact that more updates are coming. Our dedicated Germany e-invoicing page can help you to meet your compliance obligations.

Requirements to register for VAT in Germany

Companies established within the EU but outside of Germany typically do not have to register for VAT in the country. However, there are exceptions which would require a foreign business to have to register for VAT – including:

  • Buying and selling domestically without the goods leaving the country
  • Holding products in a German warehouse and selling to German customers
  • Importing into and selling goods in Germany from another EU Member State
  • Intra-community supplies (moving goods between Germany and other EU Member States)
  • Organising live events in Germany – whether for art, education or a conference
  • Selling via an electronic marketplace in Germany

More exceptions and other nuanced situations may require VAT registration in Germany. Contact us for more information.

IPT in Germany

Insurance Premium Tax (IPT) is another tax obligation in Germany to consider.

IPT in Germany is complex, providing numerous elements for insurers, brokers and other applicable parties to track – from rates to law changes. Just a handful of years ago, Germany underwent sweeping Insurance Tax Act reforms that caused uncertainty in the insurance market.

Put simply, Insurance Premium Tax is made up of five key elements. Together, the following determine the tax:

  • Location of Risk
  • Class of Business
  • Tax applicability and tax rates
  • Declaration and payment
  • Additional reporting

Find out more about Germany IPT.

Import VAT in Germany

Import VAT, known as Einfuhrumsatzsteuer in Germany, is a unique form of VAT that foreign taxpayers must know. It is charged by the country’s customs authorities when goods are imported into Germany from countries outside the EU.

Companies established outside of EU Member States must pay import VAT in Germany, including when using ports in Bremen and Hamburg. However, foreign taxpayers oftentimes can apply for reimbursement of import VAT they have paid if they register in Germany.

Invoicing requirements in Germany

German VAT invoices have strict requirements to be legally valid. Required invoice contents include:

  • Issuance date
  • Unique invoice number
  • VAT identification number for the supplier
  • VAT rate(s), VAT amount(s), and total gross amount
  • Supplier and buyer full addresses
  • Description of the goods or services (plus quantities if supplying goods)
  • Total value of the invoice
  • Details in case of zero VAT, reverse charging, intra-community supply, etc

Registration for OSS in Germany

Cross-border trade in the EU for B2C transactions was simplified with the implementation of the One Stop Shop (OSS) scheme as part of the 2021 EU E-Commerce VAT Package.

To register for OSS in Germany, taxpayers must use the ELSTER.de portal. However, this requires an ELSTER certification, which is given to companies that have registered, paid VAT or submitted a tax return in Germany.

Learn more about OSS with our dedicated overview, or contact us for additional information.

Registration for IOSS in Germany

Devised to simplify EU VAT compliance, the VAT Import One Stop Shop (IOSS) consolidates your intra-EU activities into a single VAT return.

Businesses or their local representatives must submit an electronic application to the BZSt to register for IOSS in Germany. Taxpayers who pay VAT must also specify their VAT registration number.

Read our IOSS overview, or contact our expert team to learn more.

Intrastat and EC Sales list in Germany

Intrastat is an obligation for particular companies that trade internationally in the European Union. Specifically, it relates to the movement of goods across EU Member States.

Despite their being similar enforcements across the EU, Member States have chosen to implement Intrastat rules differently and they each have their own Intrastat threshold that triggers reporting. In Germany, there is a declaration threshold of EUR 800,000 for arrivals and EUR 500,000 for dispatches in 2024.

Find out more with our Intrastat guide.

How Sovos can help with VAT compliance in Germany

The fragmented aspect of tax compliance in Germany can be demanding on resources, especially when keeping current on future updates and implementations. Sovos is a single vendor with global and local tax expertise that allows you to future-proof your tax compliance.

Choosing Sovos as a partner means choosing to reclaim your time, allowing you to focus on what matters: growing your business.

Frequently Asked Questions

Germany issues VAT refunds monthly or quarterly, depending on the business’ filing frequency. The tax authorities transfer the refund to the bank account the business provided when it registered.

Germany’s tax authorities require invoices to include specific information, including:

  • Supplier name and address
  • Buyer name and address
  • Issuance date
  • Quantity and type of goods and services
  • Total invoice amount
  • Taxable amount
  • VAT payable amount

The standard VAT rate in Germany is 19%, applying to most goods and services. There’s a reduced rate of 7% for the likes of books, cultural services, medical and dental care.

The VAT registration threshold for taxpayers in Germany is EUR 10,000, providing they haven’t opted to pay VAT in Germany through the EU’s One Stop Shop scheme.

In Germany, VAT is due when the tax point occurs. It can be paid from the day after the end of the reporting period to the due date of the VAT return being paid.

Germany does not require companies outside the EU to appoint a fiscal representative for tax purposes. Businesses can choose whether to appoint a local representative or register directly with the appropriate tax office in Germany.

In Germany, the tax point determines when VAT is due. For goods, it is typically the time of delivery. For services, it is when the service is completed.

The tax office automatically sends a tax ID number to newly registered German addresses within three weeks of registration. It will come via mail; a duplicate can be obtained from the Finanzamt.

The delivery threshold in Germany is EUR 10,000. If a Germany-based supplier delivers goods to a customer in another European company under EUR 10,000, they will pay VAT in Germany as the threshold has not been reached.

Climate-related events are an issue that impacts all industries, and the insurance industry is certainly no exception.

Beyond the challenges that insurers face in assessing the likelihood of weather-related events and natural disasters, there are also difficulties affecting Insurance Premium Tax (IPT) as countries look at ways to ensure they can fund responses to the consequences of these events. Some of these are not direct IPT measures but inevitably impact IPT, whereas others are direct IPT-related measures.

A gradual shift towards mandatory natural catastrophe insurance?

Natural catastrophe coverage is often an optional add-on to property insurance. In some countries, however, that is not the case – such coverage is mandatory. France and Spain are examples of this, with regimes in place involving the Caisse Centrale de Réassurance (CCR) and Consorcio de Compensación de Seguros (CCS), respectively.

Against a background of increasing costs due to natural disasters, recent months have seen other European countries follow suit with similar laws or proposals. Italy, for example, passed a law in late 2023 which requires companies to take out insurance policies by the end of 2024 to cover natural disasters occurring in the country. The government has authorised an Italian insurer to provide reinsurance of such risks like CCR in France, up to certain limits.

Germany and Slovenia have also seen resolutions or proposals for similar laws. In Germany, the Federal Council has called on the government to introduce mandatory natural catastrophe insurance. This is in light of the insurance protection gap relating to such coverage of properties. It remains to be seen whether the government will act based on this.

The increasing costs of weather-related events have triggered Slovenia’s national programme for protecting against natural disasters in the coming years, and a discussion of mandatory state insurance was recommended.

Additional premium amounts paid for natural catastrophe insurance can be expected to attract IPT and any applicable parafiscal charges due in these countries.

Changes in IPT due to increasing costs of climate-related events

Weather-related events have also been cited as a reason for various premium taxation changes. In France, the additional premium rates due on risks which trigger natural catastrophe coverage (property and fire, as well as certain motor coverage) are increasing. Most notably, for property and fire risks, the premium rate is increasing from 12% to 20%. As IPT is due on this additional premium, this will significantly increase the IPT due on these policies.

Climate-related issues have had a major impact on levies used to fund emergency services due on property insurance in some states in Australia, specifically New South Wales and Tasmania. There is increasing pressure to reform the levies (with mixed success) due to the spiraling costs of responding to natural disasters. The levies result in huge increases to premium values, so the Insurance Council of Australia, amongst others, has urged the states to find a more sustainable way to fund emergency services.

Sovos actively monitors changes that impact IPT and is best positioned to advise if you have any IPT queries. Contact our experts today for more information.

The taxation of insurance premiums in Hungary is unique, both in terms of the technique used to calculate the tax and how it is governed.

Regarding calculating Insurance Premium Tax (IPT), Hungary is the only country in the EU where the regime uses the so-called sliding scale rate model. It applies to both IPT and the extra profit tax on insurance premium amounts (EPTIPT), also known as the supplemental insurance tax.

The insurance premium tax law (Act of 102/2012) includes the rules of IPT. However, this law can be amended by a government decree. Government Decree of 197/2022 regulates the EPTIPT. The Hungarian Tax Office has issued guidance about the rules of insurance premium taxation, and both IPT and EPTIPT are declared on the same return template.

What kind of taxes are applicable in Hungary on insurance premium amounts?

In Hungary, insurance premium tax (IPT) and extra profit tax (EPTIPT) are levied on the premium amounts collected by the insurance companies.

What are the IPT tax rates in Hungary?

In Hungary, it is almost impossible to determine the rate and amount of the insurance premium tax for a single policy, because IPT and EPTIPT are levied on the aggregated amount of the collected insurance premium.

The sliding scale regime considers:

  1. The amount of the collected premium in the year preceding the reporting period (i.e. threshold)
  2. The amount of the collected premium in the reporting month (i.e. scales)

For IPT, the threshold is HUF 20 billion since April 2024. It was HUF 8 billion prior to that. EPTIPT has no such taxable premium threshold.

For IPT, the scale is:

For IPT, the only exception from the sliding scale regime is the Class 10 motor third party liability insurance (MTPL) premium. IPT on MTPL premium is calculated differently, hence MTPL premium amount is not part of the aggregated taxable premium. The tax rate for MTPL premium is 23%.

EPTIPT’s scale differs from those of the IPT. Although the EPTIPT computation for non-life and life policies differs, the same scales apply. The EPTIPT scale is:

The rates, as of 2024, are:

What is the basis of Insurance Premium Tax Calculation in Hungary?

The taxable basis is the insurance premium. The insurance premium is defined by the IPT Law (point 1 article 7 of Act 102/2012) as:

“The gross premium accounted for by the insurer based on accounting regulations for insurance services, including values not accounted for as gross premiums but considered as the countervalue for insurance services as coverage for insurance services, excluding premium income received from reinsurance taken from another insurance company, which is accounted for as gross income.”

MTPL premium amounts should not be considered for IPT’s sliding scale. However, the premium collected for MTPL is included in the EPTIPT non-life aggregated premium amount.

Are life and sickness policies exempt from Hungarian IPT?

Life policies are exempt from IPT, but EPTIPT is payable on premium amounts collected by insurance companies from life policies.

Sickness insurance is exempt from both IPT and EPTIPT.

Another notable exemption is the premium amount collected on certain agricultural policies.

What are Insurance Premium Tax challenges in Hungary?

Currently, the biggest challenge in Hungarian Premium Taxation is the legal environment. The Constitution and the law on special measurements in case of catastrophic environments allow the government to amend tax rules – including IPT – via governmental decrees, instead of actually changing the relevant tax law.

For example, in 2022, a governmental decree introduced a new tax: the extra profit tax on insurance premium amounts (known as supplemental IPT or EPTIPT). In 2024, the government published another decree to change the applicable brackets of the sliding scale for the IPT regime.

The Act on Insurance Premium Tax No 102/2023 was not changed in either of these cases.

Updates on IPT in Hungary

Hungarian IPT regulation is regularly changing. To keep yourself in the know, subscribe to Sovos’ tax alerts.

Here’s a brief timeline of changes to IPT in Hungary:

February 2024: Change for filing and payment of EPTIPT

March 2024: Hungary changes IsPT rates

Want to learn more about Insurance Premium Tax?

These resources can help you navigate the intricacies of Insurance Premium Tax:

Need help with Insurance Premium Tax in Hungary?

Sovos’ IPT Determination solution enables you to confidently calculate and apply IPT rates at quotation. Real-time tax updates ensure tax rates and tax applicability are always accurate.

Want to ease the burden on your tax teams? Sovos’ IPT Managed Services provides support from our team of local language regulatory specialists who monitor and interpret IPT regulations around the world, including in Hungary, so you don’t have to.

As the global e-invoicing landscape continues to shift and develop, our quarterly VAT Snapshot webinar brings you all the details on the key regulatory changes to watch.

Join Dilara Inal and Marta Sowinska from our Regulatory Analysis and Design team for a 30-minute update on the latest developments in e-invoicing regulations across Europe and beyond.

This session will cover:

Ever-changing Insurance Premium Tax (IPT) rules and regulations can be challenging to keep up with, so staying on top of the latest developments in IPT compliance is key.

Join our insightful webinar where Sovos’ IPT experts Edit Buliczka, James Brown and Jake Thorne will deep dive into the intricacies of remaining compliant in Hungary and discussing the current and the potential future impacts of the climate change to the IPT regulations across Europe and beyond.

Remaining current with the latest regulatory revisions in VAT reporting and SAF-T requirements in Poland. This webinar will deliver a comprehensive overview of recent changes to ensure you thoroughly understand the evolving compliance landscape. Gain valuable insights into essential strategies and best practices for preparing for VAT audits, mitigating risks and avoiding penalties.

The EU Directive for VAT has laid the groundwork for a harmonised VAT system throughout the different Member States. However, the implementation of the EU VAT law within the national jurisdictions still creates a disparity between its application and conditions to be met, specifically regarding some of the intra-EU simplifications to be applicable.

Following a webinar covering regulatory updates alongside key points of the VAT recovery process, this blog aims to shed light on the crucial aspects of VAT recovery – especially fast-approaching deadlines.

Understanding the nuances of VAT recovery applications is essential for businesses seeking to optimise operational costs by recovering VAT incurred in a different country. Let’s explore the fundamental aspects of the VAT recovery process.

The VAT recovery process

Businesses can reclaim VAT incurred during their operations through VAT returns if registered in the country where costs are incurred. However, for those not registered and with no obligation to do as such, alternative routes such as the EU Refund Claim or 13th Directive procedure are available – provided specific criteria are met.

Before initiating a VAT refund claim, companies must carefully evaluate their taxable activities. Failure to identify taxable activity in the relevant country may result in the rejection of the VAT recovery application. In such cases, registering for VAT becomes imperative to facilitate input VAT recovery through VAT returns, subject to each country’s rules regarding retrospective VAT registration.

Recoverable expenses

The range of recoverable expenses varies across countries, encompassing equipment, tooling, event costs, professional fees, accommodation and so on. However, due to varying regulations, conducting a comprehensive recoverability assessment based on each country’s VAT legislation is crucial before applying.

Meeting deadlines

Adhering to deadlines is critical for successful VAT recovery.

EU businesses seeking VAT refunds from other Member States must submit an EU Refund Directive application by 30 September of the subsequent calendar year. Non-EU businesses aiming to reclaim VAT incurred in EU Member States should file a 13th Directive application by 30 June of the following year.

While some countries share a common deadline of 30 September, missing deadlines may restrict refund requests. Notably, even though in most cases, these deadlines cannot be extended, there are countries like the Netherlands where refund requests can be submitted to tax authorities up to five years back rather than just for the previous fiscal year.

Understanding reciprocity

Reciprocity agreements are pivotal in VAT refund claims, with most EU Member States mandating reciprocity. Understanding these laws is essential to avoid failed attempts at reclaiming VAT in non-reciprocal jurisdictions.

Recent updates include the UK-Italy agreement under the 13th VAT Directive, streamlining VAT refund claims for UK businesses. Notably, the deadline for a 13th directive application in Italy is September 30th, 2024, for all costs incurred during 2023 (i.e., purchase invoices dated in 2023). This represents a significant advancement toward streamlined cross-border VAT recovery processes for UK businesses. Additionally, it may be advantageous for businesses to revisit already submitted 13th Directive claims in Italy that were previously on hold due to the lack of reciprocity.

In conclusion, mastering the intricacies of VAT recovery empowers businesses to enhance financial efficiency and mitigate costs effectively. By navigating the essentials outlined above, businesses can embark on a journey toward unlocking their full VAT recovery potential.

Take Action

Want to learn more about the VAT recovery process? Our expert team can help.

In Austria, the insurance premium tax law regulates the indirect tax that applies to elements of coverage under a motor insurance policy. This blog details everything you need to know about this particular indirect tax in the country.

As with our dedicated overviews of the taxation of motor insurance policies in Spain and Norway, this blog will focus on the specifics in Austria. We also have a blog covering the taxation of motor insurance policies across Europe.

Which taxes are payable concerning motor insurance policies in Austria?

In Austria, Vehicle Insurance Tax (VIT), or the so-called motor-related insurance tax, is payable in relation to:

VIT is payable in addition to the 11% insurance premium tax (IPT).

How is VIT calculated for motor insurance policies in Austria?

The calculation of VIT is complex. The tax is determined by the type of vehicle, the engine capacity/displacement and CO2 emissions for motorbikes, the performance of the combustion engine and the emission in grams per kilometer for passenger automobiles and the power of the combustion engine for all other engine types.

The date of registration is another item to consider when calculating the amount of VIT. The computation for automobiles registered before 1 October 2020 is different, however.

The following rates are effective for passenger cars registered after 1 October 2020 are as follows:

In 2020, the first component, power, was lowered by 65 Kwatt, while the second component, emission, was reduced by 115 grams per kilometre. Since 2021, the deduction has been lowered annually. Every year, the first component is reduced by one and the second by three. As a result, in 2024, the deductions are 61 Kwatt and 103 grams per kilometre.

To complicate this further, the aforementioned calculation only applies to M1 passenger cars whose CO2 emissions were established using the WLTP (Worldwide Harmonised Light Vehicle) test method. If this process is not followed, the calculation will be different.

Special rates apply to motorhomes, motorcyclists and other multi-track motor vehicles.

The computed amount is due monthly. Prior to 2020, the regularity of the payment was another aspect to consider in the computation.

What vehicles are exempt from tax in Austria?

First and foremost, VIT is required on motor vehicles weighing up to 3.5 tonnes. If the vehicle’s weight exceeds this limit, another type of tax – motor vehicle tax – is due.

The exemptions in Austria follow the usual considerations mentioned in our blog on taxation of motor insurance policies across Europe. Exemptions are dependent on:

Read our IPT Guide to learn more about Insurance Premium Tax compliance.

Take Action

If you still have questions about the taxation of motor insurance policies or IPT in Austria, speak to our experts.

Greece e-invoicing

Electronic invoicing is mandatory for B2G supplies and optional for B2B and B2C supplies.

However, the Greek authorities want to implement a nationwide B2B e-invoicing mandate as part of the e-invoicing reform. The reform started in 2020 with the roll-out of the country’s e-audit scheme called myDATA.

E-invoicing requirements across B2G, B2B and B2C transactions vary, making it a demanding task to stay on top of compliance with the country’s e-invoicing regulations. This page details the current status quo and will be updated as changes are enforced – be sure to bookmark it and revisit it to stay compliant.

At a glance: E-invoicing in Greece

Greece B2G e-invoicing

CTC Type

E-invoicing through an accredited e-invoicing service provider

Network

PEPPOL

Format of e-invoice

EN-compliant, PEPPOL BIS 3.0 (Greek CIUS)

eSignature Requirement

N/A

Archiving Requirement

5 years

Greece B2B e-invoicing

E-invoicing/CTC Type

Post-audit/Voluntary CTC e-invoicing (via an accredited e-invoicing service provider)

Network

Exchange not regulated (unless CTC e-invoicing is used)

Format of e-invoice

E-invoice format not regulated (EN-compliant, if CTC e-invoicing is used)

eSignature Requirement

N/A

Archiving Requirement

5 years

Greece B2C e-invoicing

Greece does not have a mandate for e-invoicing as far as B2C transactions are concerned. Fiscal devices currently used for issuing compliant invoices for B2C sales must follow new technical requirements for the connection and real-time reporting of B2C sales data to the myDATA platform (new generation online tax mechanisms).

E-Invoicing regulations in Greece

In Greece, there are several regulations relating to electronic invoicing. The regulations include:

  • The transposition of Directive 2014/55/EU mandates the government sector to receive electronic invoices.
  • Joint Ministerial Decision No. 52445 ΕΞ/2023, mandating the use of e-invoices for all sales made to the government.
  • Joint Ministerial Decision no. 63446/2021 (as amended by Joint Ministerial Decision no. 31781ΕΞ2022/2022), specifies the e-invoice format for B2G transactions which is compliant with the European standard (EN 16931).
  • The Ministerial Decision No. 1017/2020 specifies the e-invoice format for B2B transactions in the nation.
  • The Ministerial Decision No. A.1035/2020 dictates rules and regulations for accredited e-invoicing service providers.

Timeline: B2G e-invoicing adoption in Greece

The tax authority is rolling out the B2G e-invoicing mandate in phases. The mandate covers most public contracts, from defence to general supplies and services. The gradual implementation is ongoing, covering:

  • As of 12 September 2023, suppliers to some major government agencies (e.g. Ministry of Transport, Ministry of Digital Transformation, Ministry of Migration and Asylum, etc.).
  • As of 1 January 2024, suppliers to all central government agencies.
  • From 1 June 2024, suppliers to all other government authorities.
  • From 1 January 2025, other government expenses must be invoiced electronically (outside the scope of public procurement contracts).

Format of an e-invoice in Greece

Governments implement electronic invoices to simplify and standardise the transmission of data in transactions, and Greece is no different. The e-invoice format in B2G transactions is based on the European standard for e-invoicing (EN 16931) and PEPPOL BIS Billing 3.0.

The format of a B2B e-invoice in Greece is not regulated and largely falls in line with the obligations of the EU VAT Directive. Invoices must include information such as:

  • Issuance date
  • Date of supply
  • Supplier’s VAT number
  • Names and addresses of both supplier and customer
  • Full description and quantities of goods
  • Net taxable value
  • VAT rate and amount

CTC e-invoicing via an accredited e-invoicing service provider is voluntary. While Greece has yet to implement a nationwide B2B mandate, it has a set standard and format for taxpayers who issue e-invoices voluntarily. The e-invoice must be in a structured format compliant with the European standard.

Process of B2G e-invoicing in Greece

If you do business with a public sector entity in Greece, you must issue invoices electronically. Doing so requires you to follow a set process:

  1. Prepare the e-invoice data and send it to the accredited e-invoicing service provider.
  2. The e-invoicing service provider validates the invoice data before submitting it, using the respective services of the National Interoperability Center (KED), which is responsible for receiving all e-invoices by suppliers through the PEPPOL network.
  3. The e-invoicing service provider reports certain invoice data in a structured format and according to specific technical specifications to the myDATA platform for clearance and receives back a unique registration number (MARK).
  4. The e-invoicing service provider prepares the e-invoice based on the European standard, according to the Joint Ministerial Decision no. 63446/2021 (as amended by Joint Ministerial Decision no. 31781ΕΞ2022/2022).
  5. The e-invoicing service provider submits the e-invoice to the Access Point of the National Interoperability Center through the PEPPOL network.
  6. The National Interoperability Center receives and validates the e-invoice according to the European standard and national rules for e-invoicing.
  7. The National Interoperability Center routes the e-invoice to the competent contracting authority.
  8. The competent contracting authority handles the e-invoice according to their internal procurement and payment process.
  9. Upon receipt of the e-invoice, the contracting authority sends a response message regarding the status of the e-invoice back to the supplier through the National Interoperability Centre and his e-invoicing service provider.

Benefits of using e-invoicing in Greece

Greece provides incentives for using CTC e-invoicing through accredited service providers, as per Law 4701/2020, for the 2020-2024 tax years.

These incentives include a reduction of the statute of limitation for fiscal matters by two years and a depreciation of twice the cost incurred for acquiring technical equipment and software required to implement electronic invoicing.

Implementing e-invoicing can also be beneficial by automating and standardising your processes, reducing the chance of clerical errors and freeing up resources.

Future of e-invoicing in Greece

While the future of e-invoicing in Greece is not set in stone, the end goal seems clear.

With Greece engaging in a dialogue with the European Commission over a nationwide e-invoicing mandate, there is a chance that electronic invoicing will become mandatory for B2B transactions.

Many European countries are looking to digitize their tax systems to increase transparency for tax authorities and reduce the VAT gap – Greece appears to be moving in this same direction.

Additional obligations for VAT compliance in Greece

Electronic invoicing and myDATA are important obligations for taxpayers in Greece to be aware of, but there are more compliance needs that many need to meet.

Consider the evolving nature of tax regulations. The number of obligations and the chance of change make meeting your obligations an ongoing, demanding task.

It’s vital that you are aware of what applies to your organisation, and how to stay on top of your requirements. Find out more about Greece VAT compliance through our dedicated overview, and bookmark the page to stay updated on any regulatory updates.

FAQ

Electronic invoicing is mandatory for B2G supplies, as of September 2023, and optional for B2B and B2C supplies. However, invoice data for B2B, B2G and B2C supplies and other accounting data must be reported to the myDATA platform.

Taxpayers who transact with the public sector must issue electronic invoices based on the European standard.

The PEPPOL network must be used to exchange e-invoices between businesses and the public sector (B2G transactions).

Since 2021, companies established in Greece have been required to electronically report accounting data through the myDATA system. The implementation timeline of the myDATA mandate is ongoing.

Greece’s myDATA is a reporting obligation of ledger-type data, and it is not to be confused with e-invoicing as it doesn’t require invoices to be issued and exchanged in electronic form.

Greece mandates e-invoices in B2G transactions and allows for invoices in B2B/B2C transactions to be issued and exchanged on paper or electronically, following the standard e-invoicing rules of the EU VAT Directive or the voluntary CTC e-invoicing scheme.

How Sovos can help

Sovos’ Compliance Cloud is a complete platform for tax compliance and regulatory reporting. The platform provides one place to identify, determine and report on global tax obligations, including those in Greece.

Get in touch with us

Unlock the secrets to fruitful global trade in our latest webinar; our consulting expert Luca Clivati will provide valuable insights and guidance to help businesses maximise operational and financial efficiency when trading globally.

E-invoicing: An Overview

Turkey was an early adopter of electronic invoicing when considering the global landscape of tax digitization. As part of its larger e-Transformation initiative, the country mandated e-invoicing in 2014.

Understanding the complexities of Turkey e-invoicing and its other electronic systems can be challenging, however, and that’s why this page exists. Be sure to avoid penalties for non-compliance by exploring this mandate overview – and bookmark the page to ensure you are always on top of any regulatory changes.

Want to speak to a tax expert? Get in touch with our compliance team.

At a glance: E-invoicing in Turkey

Turkey B2B e-invoicing

CTC Type

  • E-invoice clearance with two-way application

Network

  • GIB portal

Format

  • UBL-TR 1.2

eSignature Requirement

  • Fiscal stamp or qualified electronic signature required

Archiving Requirement

  • 10 years

Turkey B2G e-invoicing

CTC Type

  • E-invoice clearance with two-way application

Network

  • GIB portal

Format

  • UBL-TR 1.2

eSignature Requirement

  • Fiscal stamp or qualified electronic signature required

Archiving Requirement

  • 10 years

Who needs e-invoicing in Turkey?

The scope that mandates e-invoicing usage in Turkey has evolved over time. Considering the cost of non-compliance, it is important to know if you fall under the requirements of the regulation.

Companies with turnovers exceeding TRY 3 million are required to use electronic invoices, though there are also sector-based parameters for the mandate that ignore the turnover threshold. This turnover exception includes:

  • Companies licensed by the Turkish Energy Market Regulatory Authority
  • Middlemen or merchants that trade fruits or vegetables
  • Online service providers that facilitate online trade
  • Importers and dealers

How to issue an e-invoice?

Before getting started with issuing and receiving electronic invoices in Turkey, taxpayers are required to register on the tax authority’s GIB portal. They need their Vergi Kimlik Numarasi – a 10-digit tax identification number – for a successful registration.

Once registered, taxpayers have a few options for issuing electronic invoices. They can either use the GIB portal, integrate the portal with their own internal applications or use a vendor like Sovos (which has its own Turkey e-invoice solution).

 

 

What are the benefits of e-invoicing in Turkey?

Besides the fact that e-invoicing is mandatory for many businesses and all public administrations in Turkey, there are several benefits of invoicing electronically.

  • Cost-saving: Reducing paper, postage and manual labour saves money
  • Time-saving: Using structured, automated electronic systems and processes saves time
  • Compatibility: The universal format of e-invoices and systems increases interoperability
  • Security: The automation, validation and authentication of e-invoices maintain integrity

Legal requirements for an e-invoice in Turkey

The e-invoice mandate in Turkey requires taxpayers to include specific information on electronic invoices. These requirements include:

  • Invoice date
  • Invoice reference number
  • Description and specification of goods and services delivered
  • Total net amount and gross amount for the order
  • Supplier details (name, address, tax ID, etc)

E-invoices are required to be secured with an eSignature. Individuals must use a Qualified Electronic Signature (QES), a more secure version of an electronic signature.

From September 2023, it will also be mandatory to include a QR code on electronic invoices (as well as other electronic document types).

E-invoicing software

E-invoicing software allows you to create and send electronic invoices online. Solutions need to meet the specifications set forth by the Turkish Revenue Authority, either integrating into your existing system or serving as a cloud platform.

Sovos’ e-invoice compliance solution allows customers to meet their compliance requirements, both in Turkey and globally. If you are part of an international organisation, our platform allows you to stay compliant wherever you do business.

The future of e-invoicing

Turkey is well ahead of most when it comes to the digitization of its tax system. This includes utilising electronic invoices, with the country mandating the use of e-invoices for specific companies on 1 April 2014. Find out more about Turkey’s e-Transformation.

That said, tax digitization is still developing globally. In the EU, the VAT in the Digital Age initiative aims to digitize tax across the region. If passed, this proposal could produce major changes to how businesses operate across the European Union – including using e-invoices and digital reporting.

The rapid yet fragmented digitization of tax worldwide only increases the importance of working with a global compliance partner like Sovos. It’s vital to take a long-term view when dealing with compliance.

Additional obligations for VAT compliance in Turkey

Turkey has a vast digital tax system comprised of many electronic systems and documents. It stepped up its tax system in 2012 with its e-Transformation initiative and produced a host of potential compliance requirements for taxpayers.

As well as e-invoicing, there are other related requirements organisations must be aware of. These include:

  • e-Arşiv Fatura
  • e-İrsaliye
  • e-Defter
  • e-Mutabakat
  • e-Müstahsil Makbuzu
  • e-Serbest Meslek

FAQ

Turkey e-invoicing is a mandate that requires certain taxpayers to issue and receive invoices electronically. According to the TRA’s regulations, taxpayers with annual revenue of over 3 million TL must register in the e-invoicing system.

Within the scope of the communiqué published by the Revenue Administration; as of July 1, 2022

  • Taxpayers with a turnover of 5 million TL for the 2018, 2019 and 2020 accounting periods, 4 million TL for the 2021 accounting period and 3 million TL or more for the 2022 and subsequent accounting periods,
  • Service providers who have a gross sales revenue of 1 Million TL for 2020 or 2021 account periods, 500 thousand TL or more for 2022 and subsequent account periods;
    • Service providers who provide electronic commerce environment for the execution of commercial activities on the internet to mediate the purchase, sale, rental or distribution of goods or services,
    • Owners or operators of websites that publish advertisements related to the sale or rental of real estate, motor vehicle vehicles belonging to real and legal persons on the internet, and internet advertising service agents who are engaged in mediating the publication of advertisements on the internet,
  • Those who have a gross sales revenue of 1 Million TL for the 2020 or 2021 account periods, 500 thousand TL or more for the 2022 and subsequent accounting periods;
    • Those who sell goods or services on their own or their intermediary service providers’ websites or any other electronic environment,
  • Taxpayers who have a gross sales revenue of 1 Million TL for the 2020 or 2021 accounting periods, 500 thousand TL or more for the 2022 and subsequent accounting periods
    •  Those who make real estate and/or motor vehicle, construction, manufacturing, purchase, sale or rental transactions and taxpayers who are in mediatory activities for these transactions,
  • Hotel businesses that provide accommodation services by obtaining investment and/or operating certificates from the Ministry of Culture and Tourism and municipalities, which have a gross sales revenue of 1 million TL for 2020 or 2021 accounting periods, 500,000 TL or more for 2022 and subsequent accounting periods, must switch to e-invoice.

Also:

  • EMRA licensed taxpayers in the list numbered ÖTV I (Special Consumption Tax),
  • Taxpayers who manufacture, build, and import the goods in the list numbered ÖTV III,
  • Taxpayers who trade fruits and vegetables as brokers or traders,
  • Health service providers who have signed a contract with the Social Security Institution and all taxpayers who supply medical materials and drugs/active substances (hospitals, medical centers, branch centers, dialysis centers, other specialized treatment centers licensed from the Ministry of Health, diagnosis, examination and imaging centers, laboratories, pharmacies, medical device and material suppliers, optician institutions, hearing center, spas, private law legal entities that offer and/or produce human medical products/products and their branches that do not have legal personality, pharmaceutical warehouses, etc.) also have to use e-Invoice.

The cancellation and return process of an e-invoice is the same as the paper invoices when viewed technically. However, in practice, some processes vary.

Find out more about cancelling and refunding electronic invoices in Turkey.

After switching to the e-invoice application, you cannot issue a paper invoice for e-invoice users. After switching to the e-invoice system, the option period granted to you is limited to seven days. During this time, you can continue to issue paper invoices.

In Turkey, e-invoices must be archived for 10 years.

Failure to comply with Turkey’s e-invoicing mandate may result in a financial penalty which equates to 10% of the value of the missed electronic invoice(s) in question. The maximum amount a taxpayer can be penalised in a year changes annually. Currently, the maximum is TRY 1,700,000.

  1. Direct Integration: Businesses can prepare their own computing infrastructures within the framework of the infrastructure and quality certifications specified by the Revenue Administration Department with technical guidelines. They can carry out their processes with their own infrastructures that work integrated with the GIB. 
  2. GİB Portal: The application can be used by entering invoices through the Revenue Administration Portal served by the Revenue Administration. 
  3. Special Integratorship: Companies such as Sovos, which have received a special integrator permission from the Revenue Administration, can be easily started by quickly switching to the e-Invoice application.

It is very easy to use e-invoices with Sovos. If taxpayers who will electronically invoice with the special integrator method prefer the Sovos solution, they are given all kinds of support for an easy transition to e-invoice.

Unlike the GİB Portal method, there is no additional process required for e-invoice backup and storage with Sovos. If taxpayers who use e-invoice with the private integrator method prefer the Sovos solution, all incoming and outgoing invoices are stored securely in our developed infrastructure without paying an additional fee. (This retention is provided retrospectively for 10 years during the period of being a Sovos customer.)

Being obliged to use the e-invoice application within the framework of the conditions determined by the Revenue Administration is a term used for taxpayers. The regulations made regarding these conditions and limitations are announced by the notifications published by the GIB at regular intervals. In this context, many companies become e-invoice taxpayers within the scope of these requirements.

After switching to the e-Invoice application, you cannot issue a paper invoice for e-invoice users. After switching to the system, you are granted an option period of seven days. During this time, you can continue to issue paper invoices.

Since e-invoices are subject to the same provisions as paper invoices, the provision valid for paper invoices in Article 231 of Tax Procedure Law (VUK) No. 213 also applies to e-invoices. Accordingly, the issuance period for e-invoices is determined as seven days. According to the article, e-invoices must be created on the system and forwarded to the recipient within seven days.

Companies using SAP can benefit from Sovos’ SAP Packages for an end-to-end e-Transformation solution and start using the product without additional integration. Companies that use other ERP/Accounting Software can use their products without additional integration with the Sovos ERP Adapter solution. In integration situations where the Sovos Adapter is not covered, companies can use the Sovos API Documents to integrate with the Sovos APIs. They can access and start integration via https://api.fitbulut.com/servis/#/eInvoice.

The management of e-invoices that come with the Sovos solution is in your hands. Thanks to our user-friendly interface, you can easily access the invoice you want and archive the invoices you make transactions with in a few clicks. In addition, by providing increased control over certain invoices with the colour, display and business rules you will determine on the invoices; you can facilitate the invoice management processes of your users.

E-invoices are issued and received only between taxpayers who fall under e-invoicing obligations. The recipient and the sender must be registered in the GİB e-invoice application.

You can check whether your customer is registered on the electronic invoice from the e-Invoice-registered users list of the Revenue Administration. As another method, a query is made with VKN/TCKN from the e-invoice-registered user inquiry screens from the portal.

According to the Tax Procedure Law, the invoice must be issued within seven days from the date of service or delivery of the goods. It is possible to retroactively issue e-invoices if the seven-day period rule is followed. Technically, the portal has no restrictions.

No changes can be made to the e-invoice sent. In this case, a new electronic invoice is created upon the rejection of the invoice from the other side. Cancellation and refund transactions vary in basic e-invoicing and commercial e-invoicing scenarios.

How to be compliant with Sovos

Sovos has software that was built specifically to help customers meet their e-invoicing obligations in Turkey. Whether you integrate it into your system or use our cloud platform, it speeds up processes and provides immediate clarity for the status of your invoices.

As well as your organisation’s need to meet requirements in Turkey, the global tax digitization continues. If you operate internationally or plan to do so in the future, it’s becoming increasingly important to choose a compliance partner that monitors regulatory changes around the world. This is where Sovos steps in.

Organisations of all shapes and sizes trust Sovos with tax – including e-invoicing compliance – allowing them to focus more time and energy on their core business.

Get in touch with us

Keeping up with e-invoicing requirements has never been a bigger task, especially if you operate internationally. Join us as we share the latest information necessary to successfully navigate the latest updates to the global e-invoicing landscape. This webinar will cover:

• Expansion of Romania’s e-transport mandate since December 2023
• Development of Spain’s SIF/Verifactu requirement
• Postponements in Portugal
• The legislative process for B2B Public Administration mandatory e-invoicing in Germany and Belgium
• Important dates to be aware of in Poland
• Recent changes to Malaysia’s e-invoicing mandate
• Date changes and key features in Israel

Sovos​, the always-on compliance company,​ today announced a joint business relationship with the Belgian PwC Firm PwC Business Advisory Services bv/srl (hereinafter: “PwC​”),​ leveraging the companies’ complementary tax and advisory service expertise and solutions to address vital e-invoicing and e-reporting needs.

Through this joint business relationship, Sovos and PwC clients can access comprehensive services to adeptly tackle the ever-evolving regulatory challenges linked to e-invoicing and e-reporting, as additional countries look to join the more than 80 countries worldwide with existing e-invoice requirements.

Through implementation of the Sovos Compliance Cloud, organisations will be able to identify and document client e-invoicing regulatory requirements across various markets, evaluate existing processes and technology, and align business objectives. Introduced in February, the Sovos Compliance Cloud is the industry’s premier unified, cloud-based tax compliance and regulatory software platform that provides a holistic system of record for global compliance.

“As companies navigate an increasingly interconnected and dynamic marketplace, the need for ​a ​more integrated e-invoice process has never been more crucial,” said Ellen Cortvriend, partner, of PwC in Belgium. “The Sovos joint business relationship allows us to deliver excellence in an e-invoicing-led global tax compliance project today, with the ability to streamline the e-invoice process even more over time.”

“With many clients of PwC ​in ​Belgium facing imminent e-invoicing mandates, the Sovos Compliance Cloud platform ensures a quick and successful integration,” said Alice Katwan, president of revenue, Sovos. “Rapid and complex compliance changes create both tax and IT challenges, from needing immediate tax determination at the point the invoice is raised, to the integration of validated e-invoices with periodic and SAF-T reporting. By reducing the operational burden and providing a singular data view into their compliance posture, Sovos and PwC allow companies to unlock tremendous business value.”

For business leaders seeking to understand more about the events driving regulatory changes and strategies to stay ahead of the compliance risk curve, PwC and Sovos compliance experts will host a complementary webinar, Have We Hit a Tipping Point for Global Indirect Tax?, on 11 April 2024 at 2 p.m. GMT. Registration is now open.

About Sovos 
Sovos is a global provider of tax, compliance and trust solutions and services that enable businesses to navigate an increasingly regulated world with true confidence. Purpose-built for always-on compliance capabilities, our scalable IT-driven solutions meet the demands of an evolving and complex global regulatory landscape. Sovos’ cloud-based software platform provides an unparalleled level of integration with business applications and government compliance processes.

More than 100,000 customers in 100+ countries – including half the Fortune 500 – trust Sovos for their compliance needs. Sovos annually processes more than 11 billion transactions across 19,000 global tax jurisdictions. Bolstered by a robust partner program more than 400 strong, Sovos brings to bear an unrivaled global network for companies across industries and geographies. Founded in 1979, Sovos has operations across the Americas and Europe, and is owned by Hg and TA Associates. For more information visit https://sovos.com and follow us on LinkedIn and Twitter.

About PwC
At PwC, our purpose is to build trust in society and solve important problems. We’re a network of firms in 151 countries with more than 364,000 people who are committed to delivering quality in assurance, advisory and tax services. Find out more and tell us what matters to you by visiting us at www.pwc.com.

PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see www.pwc.com/structure for further details.
© 2024 PwC. All rights reserved.

Stay updated on VAT Reporting and SAF-T with Sovos’ webinar. Explore legislative changes, prepare for VAT Recovery deadlines, and gain insights into SAF-T updates for Portugal, Bulgaria and Poland. Understand recovery claims essentials, crucial with the nearing 13th Directive deadline.

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.  

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.