Liechtenstein is one of many countries with Insurance Premium Tax (IPT) requirements, specifically the Swiss Stamp Duty and Liechtenstein Insurance Levy.
This blog provides an overview of IPT in Liechtenstein to help insurance companies remain compliant.
What kind of taxes are applicable in Liechtenstein on insurance premium amounts?
In Liechtenstein, there are two types of taxes that apply to premium amounts received by insurance companies:
Swiss Stamp Duty (CHSD)
Liechtenstein Insurance Levy (LIL)
These taxes complement each other. LIL is only applicable if CHSD is not applicable.
Swiss Stamp Duty is applicable in Liechtenstein based on Customs Union Treaty of March 29, 1923, which regulates the federal rules of stamp duties. Liechtenstein levy on Insurance premium amounts only applies if the Swiss stamp legislation does not apply.
It is necessary to highlight that Liechtenstein is a member of the EEA. As a result, the Location of Risk provisions outlined in the Solvency II Directive apply to LIL.
Therefore, to determine whether a premium amount triggers LIL, the rules of the referred Directive should be applied. This is not the case for Swiss Stamp Duty.
Premium payments made by Liechtenstein resident policyholders and/or to insurance companies based in Liechtenstein are generally subject to Swiss Stamp Duty.
What are the tax rates in Liechtenstein?
Premiums on non-life insurance policies are taxable at the rate of 5% and life policies at a rate of 2.5%, unless one of the exemptions listed in the regulations apply. These rates and exemptions apply to both CHSD and LIL.
Examples of exemptions include:
Policies covering accident
Transport of goods
Unemployment insurance
Hail insurance
Livestock insurance risks
Reinsurance policies
What is the basis of a CHSD and LIL calculation in Liechtenstein?
For the Liechtenstein Insurance Levy, the taxable basis is the premium payments based on an insurance relationship created by an insurance policy where the location of risk is deemed to be in Liechtenstein.
Whereas, for the Swiss Stamp Duty, the taxable basis is the premium payments for insurance:
based on a domestic portfolio of a domestic Liechtenstein insurer
that are paid by a domestic policyholder having an insurance contract with a foreign insurer
What are the CHSD and LIL filing and payment frequencies in Liechtenstein?
CHSD is filed on a quarterly and paid alongside the submission of the tax return. On the other hand, LIL is due biannually.
Each return is due within 30 days following the last day of the reporting period.
What are the penalties and interest for CHSD and LIL in Liechtenstein?
In case of late payment, a default interest should be paid on the amounts paid late. The interest rate is determined by the Swiss Federal Department of Finance.
What are the challenges for Insurance Premium Tax in Liechtenstein?
The main challenge is to determine which tax is due, CHSD or LIL. Secondly, it is challenging to determine whether the premium amount and the risk covered are exempt from taxation. The list of exemptions is long.
If LIL is due, these returns can only be filed by a fiscal representative based in Liechtenstein. It can be challenging to find one locally.
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 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:
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.
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.
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.
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)
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
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.
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.
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.
In less than six months, Poland is going to introduce its long-awaited CTC clearance e-invoicing mandate – a tax reform that will impact a large amount of businesses.
It has been possible to issue and receive e-invoices voluntarily via Krajowy System E-Faktur (KSeF) since January 2022, but from 1 July 2024 it will become mandatory for suppliers and buyers that are in scope of mandatory e-invoicing to do this via KSeF.
A detailed understanding of the new regime, plus timely and proper preparation, is critical for compliance. Whilst there is a six-month grace period on financial penalties, non-compliance can negatively impact your business in many other, often unexpected, ways.
In this 45-minute deep-dive webinar, Marta Sowińska from our Regulatory Analysis and Design team will cover:
Introduction to the mandatory e-invoicing reform in Poland
Scope of the clearance mandate: domestic vs. cross-border transactions
Key challenges:
B2B vs. B2C transactions
Latest updates on QR codes
Emergency models – also known as offline modes
Key dates and implications of non-compliance
Join us on 8 February at 2pm GMT | 3pm CET for a thorough review of the Polish KSeF e-invoicing mandate and the opportunity to submit your questions.
As tax authorities continue to digitize processes in their mission to reduce fraud and close their VAT gaps, they are introducing requirements that provide greater visibility into a company’s financial operations in the form of Continuous Transaction Controls (CTC).
It would be a mistake to think that being prepared to meet obligations in one of the countries where you operate can simply be replicated in another – CTCs are far from a ‘one-size-fits-all’ solution.
Join us on 24 January 2024 in our latest quarterly VAT Snapshot webinar series where regulatory experts Dilara Inal and Marta Sowinska will examine how tax authorities in Poland, Romania, Israel, Greece and Spain – all simultaneously implementing CTC regimes – are doing so with different sets of requirements.
Don’t miss this opportunity to learn more about these unique regimes and what they mean for your business.
Monaco is one of many countries with Insurance Premium Tax (IPT) requirements, specifically the Special Annual Tax and Fire Brigade Tax. This blog provides an overview of IPT in Monaco to help insurance companies remain compliant.
What kind of taxes are applicable in Monaco on insurance premium amounts?
In Monaco, there are two types of taxes that apply to premium amounts received by insurance companies. These taxes apply to domestic as well as foreign insurance companies who write business in Monaco, whether or not they have a branch office there.
It is necessary to highlight that Monaco is not a member of the EU/EEA. As a result, the Location of Risk provisions outlined in Directive 2009/138/EC, often referenced as the Solvency II Directive, do not apply. Therefore, determining whether a premium amount triggers Monegasque insurance premium tax or not requires understanding the local territorial rules.
SAT rates vary based on the risks covered. The lowest rate is 0.20% for policies covering export credit risks, while the highest rate is 25% for policies covering property risks with a fire element. Most taxable insurance is subject to a 7% rate.
There are various exemptions from SAT, such as life insurance and related contracts, reinsurance, and risks located outside of Monaco.
There is a fixed rate of 9% for Fire Brigade Tax.
What is the basis of SAT and FBT calculation in Monaco?
The taxable premium is the taxable basis for both SAT and FBT. It is defined as the sum stipulated for the benefit of the insurer, including any extra fees or charges paid directly or indirectly by the insurer. The taxable basis for FBT can be different from SAT.
What are the SAT and FBT filing and payment frequencies in Monaco?
SAT and FBT are filed quarterly on one return. The payment must be made alongside the filing. The settlement deadline is the tenth day of the third month after the reporting period ends.
In addition to the quarterly return obligation, insurance businesses must file an annual return by 31 May of the year after the reporting year.
What are the penalties and interest for SAT and FBT in Monaco?
Penalties are imposed for payment delays, as well as inaccuracy, omission, inadequacy, or any other violations that may cause damage to the Monegasque treasury.
The late payment interest rate is 6%, and is charged on the entire month, regardless of when in the month the late payment becomes due. For every other error, the default penalty is EUR 150 or EUR 1,500. The latter applies if the violated legal provision is punishable.
What are the challenges for Insurance Premium Tax in Monaco?
The fiscal representation regulations are the most difficult aspect of Monegasque insurance premium taxation. A foreign insurance business must have a representative authorised by the Minister of State to declare taxes in Monaco.
This representative should be a private individual and is fully liable for the payment of any Monegasque duties and fines. In addition, a certain amount of guarantee is payable if the representative is not based in Monaco.
Poland is one of many countries to use the Standard Audit File for Tax (SAF-T) to streamline tax compliance and reporting for businesses. The country was one of the first in Europe to replace the traditional VAT return with SAF-T.
Poland introduced its version of SAF-T, known as Jednolity Plik Kontrolny (JPK), in 2016, making monthly submissions of JPK_VAT compulsory for all taxpayers in 2018.
In 2020, JPK_VAT combined with the VAT return and is submitted with a declaration per the frequency of the VAT Return (monthly or quarterly).
Submission of the remaining seven JPK structures is upon request of the tax authority in the event of an audit.
The Poland SAF-T framework consists of eight JPK structures:
JPK_V7M/K
declaration for records of VAT purchases and sales combined
JPK_FA
for VAT and VAT invoices
JPK_WB
for bank statements
JPK_PKPIR
for revenue and expense ledger
JPK_EWP
for revenue account
JPK_KR
for accounting books
JPK_MAG
for warehouses
JPK_FA_RR
for flat rate VAT invoices
Other than the monthly or quarterly periodic submission of JPK_V7M/K, submission of all other JPK structures is on demand.
However, from 1 January 2025, reporting of JPK EWP, JPW PKPIR, and JPK_KR will become a periodic reporting obligation.
Timeline SAF-T in Poland
1 July 2016: SAF-T introduced in Poland in the form of JPK files
1 January 2018: Poland mandated JPK_VAT for all taxable persons
1 July 2018: Taxpayers must be able to produce accounting documents in JPK structures
1 October 2020: JPK_VAT with declaration consolidates the VAT Return and JPK_V7M/K
1 July 2021: Amendments to the mandatory JPK_V7M/K adopted
1 January 2022: Amendments to the JPK_V7M/K structure including changes to better align it with the EU VAT e-Commerce package
1 January 2025: Reporting of JPK EWP, JPW PKPIR, and JPK_KR becomes a periodic obligation
Understanding JPK VAT and SAF-T in Poland
One of the eight JPK structures in Poland is JPK_VAT, a declaration combining VAT purchase and sales records. As of 2020, JPK_VAT must be sent alongside VAT returns to the tax authority.
JPK_VAT with the declaration has two variants, depending on the submission frequency of the VAT return:
JPK_V7M for taxpayers settling VAT monthly.
JPK_V7K for taxpayers who settle VAT quarterly.
Submission of JPK_V7M and JPK_V7K is on the 25th of the month following the reporting period.
The other SAF-T JPK structures for VAT are JPK_FA for VAT invoices and JPK_FA_RR for flat-rate VAT invoices. JPK_FA and JPK_FA_RR are both submitted on demand.
Implementing SAF-T as a business
SAF-T requires additional data to analyse and authenticate the accuracy of documentation. All data submitted in the SAF-T consolidated submission must be accurate and complete to ensure compliance.
Data for SAF-T requirements is often extracted from multiple sources for a single report and combining this data can be difficult.
The data required for SAF-T differs significantly from other reporting obligations that businesses might be familiar with. The XML format required for reports makes it difficult to review, compare or test reports ahead of submissions.
As well as Poland’s SAF-T requirements, taxpayers need to also be aware of the KSeF e-invoicing mandate. Poland’s continuous transaction control (CTC) e-invoicing system is mandatory as of 1 July 2024, expanding to VAT-exempt taxpayers in 2025. Read this overview for a general introduction toPoland VAT compliance.
JPK_VAT with a declaration is an electronic document that includes both VAT records, combining information on purchases and sales and VAT returns (VAT-7M and VAT-7K).
Yes, SAF-T is mandatory in Poland. JPK VAT with a declaration must be sent to the tax authority on a periodic basis, while other types of JPKs are sent on demand.
Failure to comply with the SAF-T requirements in Poland can lead to penal and fiscal sanctions, based on a misdemeanor or a felony. If the value of the reduction of the tax liability exceeds PLN 10,000, it is a crime.
Submission of JPK_VAT with the declaration (JPK_V7M and JPK_V7K) is on the 25th day of the month following the reporting period. Other JPKs are submitted to tax authorities within three days after receiving a request from the tax authority.
Our Solution capabilities for Poland SAF-T
Data Extraction
Painlessly aggregate and consolidate data from a wide range of source systems complying with Poland’s SAF-T requirements including JPK files.
Check the accuracy, integrity and quality of complex data structures required by Poland SAF-T to give you peace of mind before you submit your JPK files to the tax authority.
Ensure that all required data sets from accounting entries, sales and purchase transactions, asset depreciation, stock movements and more, are mapped seamlessly into Poland’s JPK schema, ready to be analyzed and submitted to the tax authority.
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.
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.
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.
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.
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.
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.
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.
The convergence of traditional Value Added Tax (VAT) and transactional compliance regimes is creating new obligations and responsibilities for companies doing business around the world. When it comes to VAT, compliance is so much more than just reporting.
Here are six pitfalls you should avoid in the pursuit of VAT compliance:
1. Making the wrong VAT decision at the outset
Companies with multijurisdictional supply chains must ensure their VAT determination decisions are accurate every time. Managing the validation process with VAT Determination software that checks validity before invoices are cut can save time and improve data accuracy from the outset.
It’s also best practice to complete your buyer VAT ID checks at this point in the process to avoid nasty surprises later. Checking manually can be incredibly resource-intensive so using a solution that can automate this for you can save both time and hassle.
2. Not having a legally valid invoice
To be considered legal for VAT purposes, invoices need to meet a specific set of requirements which vary by jurisdiction. Without legally valid invoices, you may be presented with a host of problems when the time comes to reclaim input VAT. If you have accepted an invoice that doesn’t tick the boxes that make it legal for VAT purposes, you invite the scrutiny of the tax authorities.
Aside from possible fines, the delay while anomalies are reviewed can impact your cash flow and cause reputational damage. Even in a paper world, VAT deduction is not permitted for improperly formatted invoices.
3. Missing reporting deadlines
With VAT obligations always growing and adapting, the pressure on internal tax teams is greater than ever. Each government has its own approach to penalties for late submissions or overdue payments. Manual processes can no longer be relied upon to meet the demands of the authorities on time, and with accuracy.
It’s possible to streamline the reporting process using software, outsourced services or a hybrid approach; what’s best for your business depends on how your tax team is organised.
4. Manual error
With new requirements coming thick and fast, teams are working harder and faster. As a result, opportunities for manual error are at an all-time high.
Manually processing VAT invoices can be incredibly time-consuming and leaves room for oversight and human error. Even individual errors can lead to bigger problems down the line, attracting the attention of the authorities and impacting your ability to do business.
5. Challenges with data extraction and mapping
Extracting the right data from the appropriate system modules, and then processing and mapping it so that it can be summarised, is a complicated and detailed task. To complicate matters further, each jurisdiction has its own unique reporting requirements you must meet. Automating these processes can improve accuracy and your ability to comply.
6. Not reviewing data prior to submission
Preparing VAT Returns, EC (European Commission) Sales Lists, Intrastat Declarations and other country-specific reports for regular submission can be demanding. Add in the need to prepare a SAF-T (Standard Audit File for Tax) report and the complexity intensifies. SAF-T requirements differ by country, including transactional data (about sales and purchases) and accounting data at a minimum, but often need information about assets and inventory as well.
Combining detailed data from different source systems with an exacting submission format means the report cannot be easily eyeballed to check for possible errors. Tax Authorities use software to analyse the SAF-T filings they receive and decide where to follow up with further auditing. To safeguard the quality of the submission and avoid a call from the tax authority, it’s essential that data is thoroughly analysed before it’s submitted – ideally using tools of the same calibre that each Tax Authority is using.
It’s never been more important to seek the right advice for VAT. Admitting you need help can be a daunting but crucial step, but the fear of non-compliance should be a bigger concern.
Simply put, there comes a time for every multinational organisation when managing complex tax obligations in-house just isn’t viable anymore. Consolidating your compliance with Sovos gives you access to industry-leading software, consulting services and regulatory experts, all of which are focused on ensuring you’re compliant now and will remain so in the future.
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 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:
General Ledger
Accounts Receivable
Accounts Payable
Fixed Assets
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.
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.
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.
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.
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.
A reactive or ad hoc approach to tax compliance across the markets you do business in can mean the authorities have a better overall view of your data than your own internal teams. How confident are you that you have the same view of your data as the tax authorities?
Staying informed about VAT Reporting and SAF-T can be challenging when it requires keeping up with ever-changing and demanding regulations.
Ensuring you are well-informed about the latest updates from tax authorities is a crucial step in preparing for potential consequences.
In Sovos’ most recent quarterly update webinar on VAT Reporting and SAF-T, Regulatory Counsel Inês Carvalho explores the most recent legislative amendments and their potential impacts on your business.
During this webinar, our expert will cover:
Reporting news in Hungary, Belgium and Romania
SAF-T implementation in Bulgaria
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.
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.
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.
What else is required for full VAT compliance in Spain?
Spain is a notoriously complex country where VAT compliance is concerned. The tax authority has numerous rules in place that businesses need to be aware of to be fully compliant. For an overview read this comprehensive page about VAT compliance in Spain.
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.
EU-based companies must grapple with VAT charges on a myriad of goods transactions within the EU. As a manufacturing company, this intricate web of varying VAT rates can pose significant challenges. Choosing the right EU entry point is a pivotal decision, complicated by each country’s unique VAT regulations. Compounding the complexity, you may not always know the precise location of your goods in transit.
Manufacturers face supply chain disruptions, potentially jeopardising their already sophisticated operations. The question is, where should you commence your VAT journey?
Our VAT expert Russell Hughes guides you in this immersive webinar, where you will gain insights into:
The Current Landscape of the Manufacturing Industry
VAT Challenges and Strategies
Futureproofing Your VAT Strategy
Join us on this transformative journey through the VAT labyrinth and gain a competitive edge in the EU market. Don’t miss this opportunity to optimise your expansion strategy.
Join our insightful Insurance Premium Tax webinar where Sovos’ IPT experts James Brown and Khaled Cherif delve into the lesser-known, insurer-borne taxes in Belgium, France and Ireland. These taxes, whilst not directly charged to policyholders, can significantly impact insurers’ bottom lines.
Explore the intricate landscape of the following areas, considering the impact that they can have on insurers’ financials:
Belgium: INAMI Taxes
France: MRPF (Major Risk Prevention Fund)
Ireland: Stamp Duty
Discover the background to these taxes and how you can ensure compliance with their requirements to mitigate business risk and maximise profitability. Don’t miss this opportunity to shed light on the hidden financial burdens that can significantly affect your insurance business.
When it was announced recently that the introduction of a new French e-invoicing mandate had been delayed until September 2026 there was a collective sigh of relief amongst many in the tax and finance world. More time to adequately prepare, put systems and methodologies in place and have your business ready to be compliant from the get-go.
Sounds optimal, but let’s focus on reality. First, the reported delay is a bit deceiving. While it may not officially take effect until 2026, you only have a matter of months to get prepared to participate in the extended trial. Human nature may be to push it to the side and focus on more short-term deadlines. However, to not take advantage of the extra time provided would be shortsighted at best.
Here are five ways you can make this extra time work for you:
Take time to fully understand the mandate and how it impacts your organization. Be prepared to answer questions such as, where will e-invoicing and e-reporting data come from? Do we need to involve IT. Use this time to eliminate surprises.
Study and consider what other aspects of the business may be impacted by this mandate. Understand what other business data is required for a smooth integration and approvals. Consider confidentiality and data privacy.
Begin to align internal processes, workflows and systems in preparation for impending changes. This is your opportunity to test different approaches and workstreams to ensure a high-level of efficiency. How will you manage the process and who in your organization will have operational responsibility when extended trials go live?
The first list of officially registered service providers will go live in spring, 2024. Use this time to do your research on which service providers make sense for your organization, both during the trial period and as a potential long-term partner.
Evaluate your current compliance management strategy. As you begin working with a registered service provider through the trial period, consider how this differs from your approach to other government mandates. What can you learn from this experience and what other areas might you be able to improve upon?
Businesses will soon be able to register proactively for the pilot program, which has been designed to allow businesses to test the PDP platform. This program is intended to build knowledge and confidence and ensure businesses are on the path to readiness.
Therefore, it would be prudent to regard the delay as a mere six-month postponement, with the beginning of the pilot program acting as the de facto starting date. To understand the full impact on their business processes and data flows, companies will need to thoroughly test up to 36 use-cases.
The good news is that the many software vendors helping companies to streamline their purchase-to-pay and order-to-cash processes will be eager to test the compliance of their solutions as early as possible in what has become a completely new ecosystem.
We are proud to say that Sovos is one of the first 20 candidates for service provider (PDP) accreditation in France and as such, will be fully prepared to assist your organization through the trial process and beyond.
Take action:
Looking for more information about how to comply with the French Mandate?
Voluntary CTC e-invoicing, performed through service providers who must meet certain certification criteria
New generation cash registers which report B2C data to myDATA in real time
Recently, the introduction of an e-transport mandate was included in the country’s VAT reform strategy, although not much detail has been published yet.
More progress has been made in implementing the myDATA scheme and the new cash registers than for CTC e-invoicing. However, in the last few months, the authorities have taken steps towards setting up the right framework to make CTC e-invoicing – which is currently voluntary for B2B transactions – mandatory for all.
myDATA e-audit reform
myDATA went live as a voluntary system in 2020 and followed a gradual implementation timeline which is ongoing. It is an e-audit system that requires taxpayers to report transactional and accounting data to the tax administration, in real-time or periodically, which populates a set of online ledgers maintained on the government portal. The goal of myDATA is for the online ledgers to be the only source of truth of the taxpayer’s tax and financial results, and for their respective information to pre-fill the taxpayer’s VAT returns and financial statements.
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 allows for invoices (in B2B transactions) to be issued and exchanged on paper or electronically following the standard e-invoicing rules of the EU VAT Directive.
B2B e-invoicing reform in Greece
In parallel with the roll-out of myDATA, the authorities established an accreditation framework for e-invoicing service providers and introduced a voluntary e-invoicing scheme involving accredited entities. These entities are accredited by the government to perform certain functions, namely:
Issuance of invoices according to certain format and content requirements
Protection of integrity and authenticity of the invoice
Reporting to myDATA according to the specifications
Compliant archiving of e-invoices and delivery to the buyer may also be performed
To encourage the uptake of CTC e-invoicing, the government provided several incentives to businesses to use e-invoicing facilitated through accredited service providers. It also obliged businesses who opt for CTC e-invoicing to use no other methods to fulfil the myDATA requirements e.g., ERP reporting, except through accredited service providers. This implies that a business selecting CTC e-invoicing for its B2B transactions must use the same method for issuing and reporting all other invoices, including B2G transactions, and vice versa.
B2G e-invoicing reform in Greece
CTC e-invoicing became mandatory for B2G transactions on 12 September 2023 for VAT-registered suppliers to certain government agencies. The mandate will continue to roll out in phases with the next main milestone coming up in January 2024. This obligation covers the vast majority of public contracts, from defence and security to general supplies and services, with some exceptions (e.g. contracts in defence and security which are classified as secret).
With the introduction of the B2G e-invoicing mandate, the use of CTC e-invoicing has indirectly become mandatory for B2B transactions too, encompassing both issuance and reporting to myDATA. It means that businesses in the scope of the B2G e-invoicing mandate have the obligation to use CTC e-invoicing through accredited e-invoicing service providers to issue and report both their B2B and B2G e-invoice flows to myDATA.
While a B2B e-invoicing mandate cannot be introduced without prior approval by the European Commission, the Greek Ministry of Finance announced that it has started a dialogue with the Commission to discuss the conditions required to implement a nationwide mandate.
Although an ambitious timeline, the Ministry envisions a full implementation of a B2B e-invoicing mandate within 2024.
Looking ahead
Clearly, Greece’s CTC initiatives are in line with the EU paradigm shift towards increased governmental control over transactional and accounting data – it recognises the benefits of tighter tax compliance and taking steps to close its tax gap.
Significant progress has been made, with myDATA operational since 2021. With the addition of CTC e-invoicing and the e-transport mandate in the VAT reform strategy, the Greek government and businesses face a demanding period in the coming years.
E-documents or electronic documents are rapidly growing in usage across businesses of all shapes and sizes, in countries around the world.
While the automated exchange of e-documents is a relatively new phenomenon which is being adopted on a country-by-country basis, there is basic universal information that your business would benefit from understanding – and potentially utilizing.
This blog will serve as your one-stop shop for required e-document knowledge.
What is an e-document?
An e-document is an electronic transactional document or message and is typically used in an automated business process.
As the digitisation of business accelerates, so too does the use of electronic documents – whether that be an electronic invoice sent in real-time to a national tax authority or an electronic goods receipt note exchanged between companies.
The difference between electronic documents and other digital documents such as PDFs is that e-documents are machine-readable and are generally exchanged by online platforms or software.
That said, there are numerous types of e-documents and there is little standardisation as each country has its own stance and potential mandate on their adoption. The European Union has long been working on its approach to e-documents for increased interoperability with definitions and rules as part of its efforts under the eGovernment Action plan and eIDAS regulation to facilitate digital transactions and services in the EU.
In addition, the UK recently adopted the UK’s Electronic Document Trade Act which is a huge step towards the digitization of trade documents and potentially paperless global trade.
Types of e-documents
There is a wide variety of electronic documents to suit a number of applications across business, helping to streamline workflows and operations, facilitate cross-border trade and save on costs.
Other electronic documents that are used in some countries include:
E-purchase orders
E-credit & e-debit notes
E-goods receipt notes
E-payment instructions
There has been a notable implementation of e-documents in transport in recent years, with the likes of Romania adopting a system that requires taxpayers to use an electronic waybill system to obtain clearance of the transport document before the transport of goods begins. Read our dedicated blog to find out more about the global rise of e-transport documents.
One particular e-document that has had an exponential rise in utility over the past few years is the e-invoice. Electronic invoices have grown in popularity as countries develop their continuous transaction controls (CTC) and e-invoicing regulatory obligations. The likes of France, Spain and Poland all plan to introduce e-invoice mandates, requiring taxpayers to send invoices electronically.
There is a host of reasons that electronic documents can be beneficial, which explains why tax administrations globally are implementing e-document mandates.
A primary reason for the use of e-documents is that they generally allow for the automation of workflows, increasing safety, accuracy, transparency and cost-saving for the involved parties. Automating the process of generating and exchanging documentation reduces the risk of error, allows for seamless transmission of information (including to tax authorities who seek greater transparency) and reduces the reliance on paper (providing an environmental benefit).
Another reason businesses use electronic documents is simply because they are mandated to do so as part of tax digitization controls. An increasing amount of tax authorities are making it an obligation to send documents electronically, and facing a penalty due to non-compliance is not desirable. As CTC regime adoption grows, so too does the need for businesses to meet their new e-document obligations.
Compliance conditions of e-documents
The compliance conditions of e-documents vary depending on the national rules, but there are some typical conditions across regimes.
In the context of tax digitization controls, the conditions that apply to some of the most regulated e-document types, such as the e-invoice, include:
Following a specific document format (as dictated by the relevant authority)
Ensuring authenticity and integrity (through the use of e-signatures or other validation methods)
Using the tax authority’s designated online platform or software for transmission
Archival of e-documents for a specified period of time and by implementing certain security measures
The recipient must consent to receiving electronic invoices (unless e-invoicing is mandated)
Producing and storing system documentation describing the e-invoicing/archiving system and process
What’s the difference between a digital document and an electronic document?
The difference between electronic documents and digital documents is a hot topic. It’s easy to get confused between the two considering that “digital” and “electronic” are used interchangeably by many, but it’s important to understand the difference.
Digital documents are often a digital analogue of a physical document – think a scanned document, photograph, or PDF – and oftentimes are simple for people to read and digest. An example of a digital document would be an invoice sent as a PDF via email.
Electronic documents are files of data that are generated by and for computers, making them hard for people to read due to their formatting. Such data – like that seen in a structured e-invoice (e.g. XML) – is meant to be sent from one system to another without interference from humans.
How Sovos can help
Sovos’ software allows businesses to manage CTC obligations, including e-invoicing compliance and archiving.
As the world continues its digitisation, it’s important to stay on top of evolving regulations and to keep up with best practices for your business. Working with Sovos, your business can:
Automate processes
Reduce the cost of compliance
Minimise the need for ad hoc IT involvement
Stop worrying about ever-changing formats, processes and obligations
Increase efficiency by saving time, eliminating manual updates and enhancing accuracy