As some countries either introduce or consider introducing mandatory natural catastrophe insurance (e.g., Italy this year), France is ahead of the curve.
This is because France already has a specific compensation scheme in place for coverage of property against natural disasters, and has had one since 1982. The importance of the scheme is clear, as it is based on a statement in the preamble to the 1946 Constitution that French citizens are united and equal in bearing the burden of natural disasters. It is often referred to as the CATNAT or NATCAT regime.
What is the scope?
Unlike in some countries where mandatory natural catastrophe insurance may be limited to insurance of buildings, various types of insurance are within the remit of the CATNAT regime in France.
First and foremost, damage to property coverage (both fire damage and any other damage to property) triggers the insured’s entitlement to cover against the effects of natural disasters. This is extended to damage to motor vehicles and, separately, also operating losses caused by damage to property.
It is worth highlighting that insurers providing these types of insurance must include a clause in their contracts outlining their coverage of natural disasters. Any provision to the contrary is invalid.
Practical application of the CATNAT regime
Insurers collect an additional premium (the so-called CATNAT premium) representing the coverage of natural disasters at a rate set in law and based on the type of insurance, subject to exemptions. Following a change in January 2025 due to increased costs caused by climate change, the premium rate for property damage is now 20%, whilst there are rates of 9% and 0.75% in the case of motor coverage.
Insurers have a choice on what to do with this premium amount. They can choose to retain it themselves, in which case they are responsible for compensating policyholders for damage caused by natural disasters. Alternatively, they may opt to utilise the private reinsurance market. Finally, and most significantly, there is also the option for insurers to reinsure the premium with the state-backed reinsurance body, Caisse Centrale de Réassurance (CCR).
CCR only provides cover in the event of genuine natural disasters, as defined by their exceptional intensity. Floods and earthquakes typically satisfy this, whereas storms and hail do not as the insurance market can cover them as normal. Where CCR does provide compensation, it offers unlimited reinsurance coverage.
IPT implications
The CATNAT premium is subject to premium tax treatment, meaning that it also attracts IPT. Additionally, an additional insurer-borne levy due on property risks is calculated as 12% of the CATNAT premium. These are the contributions to the Major Risk Prevention Fund (or Fonds Barnier), which are included on the IPT return.
Sovos is well placed to assist both in identifying whether a particular policy is within the scope of the CATNAT regime and with the ultimate declaration and settlement of the taxes due on the CATNAT premium.
Indonesia VAT Compliance
Value Added Tax (VAT) is a significant source of revenue for the Indonesian government. It applies to most goods and services at different rates. Generally, in Indonesia, the imposition of VAT takes two forms: the input-output mechanism and the VAT collector mechanism.
Under the input-output mechanism, the supplier charges VAT to the buyer and then pays it to the tax authorities. In the VAT collector mechanism, the seller does not collect VAT. Instead, specific entities appointed by law collect VAT and remit it directly to the tax authorities.
This page provides an overview of VAT compliance requirements in Indonesia. Be sure to bookmark the page and revisit it whenever you have a question.
Due monthly, by the end of the month immediately following the taxable period 10th day of the month following the end of the tax period
VAT rates
11% (standard) 12% (luxury goods and services)
VAT rules in Indonesia
E-invoicing in Indonesia
In addition to general VAT compliance, Indonesia also has an e-invoicing mandate for almost all taxpayers.
Mandatory for VAT-registered taxpayers since 2016, Indonesia’s electronic invoicing requirements includes using a national system known as e-Faktur and largely involves issuing e-invoices for:
Businesses must register for VAT if their annual turnover exceeds a specified threshold:
Threshold: Business entities with an annual turnover of IDR 4.8 billion [approx. EUR 263 472.00] or more must register for VAT. This turnover includes all supplies of taxable goods or taxable services.
Process: Registration must be completed through the Directorate General of Taxes (DGT).
Small businesses whose annual turnover is below the specified threshold are not required to be registered for VAT. However, VAT registration is voluntary.
Penalties for non-compliance with VAT in Indonesia
Failing to comply with VAT regulations can result in administrative penalties being imposed. Criminal penalties may be imposed when businesses are late issuing tax invoices and filing VAT returns. Furthermore, penalties are also levied for failure to register for VAT on time.
Late filing of VAT returns can incur a penalty of 2% of the VAT owed per month
Late payments are subject to a 2% interest per month on the outstanding VAT amount
Late registration for VAT can result in a fine of IDR 1,000,000 (approx. EUR 55.04) being imposed
Criminal offences, including imprisonment, may be imposed for violating VAT regulations
The standard VAT rate in Indonesia is 11%, applying to most goods and services. However, since 1 January 2025 there has been a 12% VAT rate on luxury goods and services like private jets, cruise ships and luxurious houses.
Generally, the VAT rate on goods and services in Indonesia is 11%. There is, however, exceptions to this – exports of taxable goods, services and intangible goods are zero-rated.
Non-residents can recover VAT in Indonesia – depending on their status. Tourists can claim VAT refunds on eligible goods purchased from participating retailers under the “Tax Refund for Tourists” scheme. To qualify, they must hold a foreign passport and stay in Indonesia for no more than 60 days from their entry date.
Non-resident companies conducting business in Indonesia may be eligible to recover VAT, provided they are registered for VAT in Indonesia and comply with local tax filing requirements.
Non-resident companies must appoint a fiscal representative in Indonesia to comply with local tax obligations, particularly for VAT purposes. This requirement applies to foreign businesses without a physical presence in Indonesia that engage in taxable activities within the country.
To claim a VAT refund in Indonesia, you must purchase goods from shops displaying the “Tax Refund for Tourists” logo by presenting your passport. You need a valid tax invoice (with a payment receipt) for each transaction. The minimum VAT per transaction is IDR 50,000, and the total VAT from all receipts must be at least IDR 500,000.
Purchases must be made within one month before departure, and goods must be carried out of Indonesia as accompanied baggage within 30 days of purchase.
Non-resident companies conducting taxable activities in Indonesia may be eligible to reclaim VAT subject to fulfilling the VAT registration and filing requirements.
Solutions for VAT compliance in Indonesia
Complying with Indonesia’s VAT requirements becomes significantly burdensome on resources when you also operate in other countries. Each nation has its own VAT nuances, and requirements change over time.
That’s why it’s vital that you have a single compliance partner for wherever you do business. Sovos makes compliance simple, handling your tax needs so you can focus on your organisation.
Complete the form below to speak with one of our experts
Russia regulates electronic invoicing nationwide, but its usage remains mainly optional. Only transactions involving certain traceable goods require buyers to issue e-invoices.
Russia has a specific approach to e-invoicing, and this page provides an overview. Bookmark it to keep track of any updates.
While electronic invoicing for business-to-business transactions remains predominantly voluntary in Russia, resolution No. 807 dated 25 June 2019 states that specific categories of goods mandatorily require electronic invoices under the national traceability system.
The following product categories fall under Russia’s mandatory e-invoicing requirements:
Refrigeration and freezing equipment
Industrial trucks (including forklift trucks, bulldozers, graders, planners, power shovels, excavators, shovel loaders, tampers, and road rollers)
Washing and drying machines (for household and commercial applications)
Monitors and projectors (excluding television reception equipment)
Electronic integrated circuits and components
Baby strollers and child safety seats
This regulatory requirement, in effect since 1 July 2021, applies to all legal entities and individual businesses engaged in transactions involving these goods. Recipients of these products must maintain capabilities for accepting and processing electronic invoices.
B2G e-invoicing in Russia
No comprehensive mandate exists for electronic invoicing in Russia for business-to-government transactions. However, electronic invoices are widely utilised voluntarily throughout the public procurement ecosystem.
As with B2B transactions, mandatory e-invoicing applies exclusively to transactions involving traceable goods under Russia’s national goods traceability system. This regulatory framework was implemented in 2021 to enhance monitoring of trade activities within the Eurasian Economic Union (EAEU).
Timeline of e-invoicing adoption in Russia
Here are the key dates in Russia’s e-invoicing journey.
2012: Introduction of voluntary e-invoice exchange between businesses
2017: Introduction of mandatory e-invoice government clearing
1 July 2021: Implementation of mandatory e-invoicing for traceable goods
January 2024: Retention of invoices and accounting documents increased from four to five years under Order No. 236 of 2019
Russian E-Invoice Clearance
Incorporating a system of electronic invoicing, Russia introduced mandatory e-invoice government clearing in 2017 for the mandated issuance of traceable goods as well as for any voluntarily issued e-invoices. This required the production of invoices in XML as a UTD (Universal Transfer Document) format established by the Federal Tax Service.
Key components of the Russian e-invoicing system include:
42 certified Russian software providers that support electronic invoice submission with digital signatures
Electronic Document Exchange (EDE) networks that ensure secure invoice transmission
Regulatory oversight that enables Russian tax authorities to detect errors or fraud swiftly
Mandatory e-invoice retention period of five years
Specific format requirements for standardised information exchange
Characteristics of e-invoices in Russia
Russian e-invoicing compliance requires adherence to specific technical standards:
E-invoices must be generated from XML files with tags in the Russian language
Documents must be formatted according to the UTD (Universal Transfer Document) standard set by the Federal Tax Service
All invoices must be authenticated with qualified electronic signatures
Signature certificates must be issued by authorised Russian certification authorities (CAs)
Digital signatures can be prepared and stamped by certified e-invoice agents
All e-invoices must be securely archived for a minimum retention period of five years
Transmission must occur through approved Electronic Document Exchange networks
Russia only mandates the issuance of electronic invoices for select goods that fall under the country’s traceability requirements. The applicable goods include:
Refrigeration and freezing equipment
Industrial trucks (forklift trucks, bulldozers, graders, planners, power shovels, excavators, shovel loaders, tampers, in addition to road rollers)
Washing and drying machines (household and laundry facilities)
Monitors and projectors (excluding receiving television equipment)
The mandatory retention period for e-invoices in Russia is five years, which aligns with the statute of limitations for tax audits under Russian law.
Organisations must implement compliant archiving solutions that maintain document integrity while ensuring accessibility for potential tax authority inspections throughout the five-year period.
Electronic Document Exchange (EDE) networks in Russia are secure, certified infrastructure systems that facilitate the transmission of electronic documents, including e-invoices, between businesses and regulatory authorities.
Only authorised EDE operators meeting strict technical and security requirements can provide these services in Russia. The 41 certified Russian software providers typically offer access to these networks as part of their e-invoicing solutions, creating a controlled ecosystem for electronic document exchange that maintains security while enabling efficient business operations.
Hungary’s tax penalty consequences of non-compliance with tax requirements are governed by the Act on Rules of Taxation.
The law outlines a range of sanctions for non-compliance, including tax penalties, default penalties, late payment interest and self-revision fees. This blog will provide an overview of each sanction and summarise recent changes in this area.
Types of sanctions in Hungary for non-compliance
In Hungary, there are four types of payable sanctions for not complying with tax rules. While most of these sanctions are imposed by the Tax Authority, the self-revision fee is calculated and settled through self-declaration.
Tax penalty
A tax penalty is imposed as a result of an audit when the Tax Authority identifies a tax shortfall during an inspection. The standard rate is 50% of the unpaid tax, but it can increase to 200% in some cases.
Default fine
A default fine is a sanction that the tax authority may apply in case of a breach or failure to comply with tax obligations specified in legislation regarding taxes and budgetary subsidies. Most default fines are determined as fixed fees rather than a percentage. The law determines the maximum amount of this fine. The Tax Authority has the discretional right to levy it in the maximum amount, decrease it, or void it.
The amount that the Tax Authority can levy depends on the type of non-compliance and the taxpayer’s status, i.e., whether it is an entity or an individual taxpayer. For example, a default penalty can be levied for missed or late submission of a tax return.
Late Payment Interest (LPI)
LPI is charged when tax liabilities are not paid on time. The interest is calculated daily, and the rate is based on the central bank’s base rate plus five percentage points divided by 365. The Tax Office determines and assesses the amount of LPI.
Self-Revision Fee (SRF)
A Self-Revision Fee (SRF) applies when taxpayers voluntarily amend their tax returns to report a higher amount than initially declared. The SRF is calculated at a rate equivalent to the prime rate. In cases where the same return is revised multiple times, the applicable rate is increased by 50%.
The SRF must be calculated and self-declared simultaneously with the revised tax liability.
The severity of sanctions and applicable settlement rules vary based on the so-called qualification of the taxpayers. Taxpayers are categorised into three groups: Reliable, Neutral and Risky. Reliable taxpayers benefit from more lenient treatment, including reduced default penalties, whereas risky taxpayers are subject to stricter sanctions. For neutral taxpayers, standard penalty levels apply by default.
Changes to Hungary’s tax penalty regime
Recent changes to Hungary’s tax penalty regime include the following.
Increase in default fine
The Hungarian government doubled certain penalty amounts from 1 August 2024:
For individuals, the maximum default penalty increased from HUF 200,000 to HUF 400,000
For legal entities, it rose from HUF 500,000 to HUF 1,000,000
Late Payment Interest (LPI) changes
Effective from 1 January 2025, there were changes in:
Calculation method The payable LPI is calculated monthly. Previously, it was annually.
Payment date Previously, the due date was 15th November of the following year.
Based on the new rules for 2024, the LPI was payable by 31 March 2025. For the months of January to March, LPI is assessed in April and is payable by 22 April (as 20 April 2025 is a public holiday). From April 2025 onwards, LPI is levied and accounted for monthly on the taxpayers’ tax accounts and payable by the 20th of the following month.
Rounding rules Late payment interest should be paid without rounding in HUF.
Notification The Tax Office will not send notifications going forward on the amount of the payable LPI, although one will still be sent once the payment threshold has been reached. LPI will be booked on the tax account, and it should be settled monthly without notification. As a transitional rule, the notifications were sent out by the Tax Office for 2024.
Despite the change in the calculation method, no changes were made regarding the threshold under which LPI is not payable. This amount remained HUF 5,000 annually.
The Hungarian Tax Office issued a notification about the changes in LPI settlement on 11 April 2025 and published the corresponding guidance on its website on 3 February 2025.
Take Action
For further information about tax compliance in Hungary and beyond, contact Sovos’ team of experts today.
VAT in the Digital Age (ViDA) aims to modernise and simplify the European VAT system.
ViDA was officially adopted by the EU on 11 March 2025. The package took 27 months to be approved and adopted, with the initiative initially being proposed by the European Commission in 2022.
The path to adoption included many versions and consultations, which this blog outlines in a timeline.
Want to understand more about ViDA and how it will impact your business? Read our ViDA guide.
2025
25 March 2025 – ‘VAT in the Digital Age’ Published in the EU Official Journal
On 25 March 2025, the VAT in the Digital Age (ViDA) package was officially published in the Official Journal of the European Union amending the following legal instruments:
These amending acts will enter into force on 14 April 2025, with different changes taking effect from that date through to 2035.
This means that in 20 days, the first changes will take effect regarding electronic invoicing rules. Under the new framework, EU Member States will have the flexibility to introduce domestic e-invoicing mandates without needing prior approval from the EU.
11 March 2025 – EU Officially Adopts ‘VAT in the Digital Age’
The VAT in the Digital Age Package (ViDA) has been adopted by the EU on 11 March 2025, 27 months after it was initially proposed by the Commission in late 2022.
The package includes a directive, regulation, and implementing regulation, focusing on three key areas: digitalizing VAT reporting by 2030, requiring online platforms to collect VAT on short-term accommodation and passenger transport services, and expanding the online VAT one-stop-shop to simplify cross-border VAT registration.
The new rules will take effect on the 20th day after publication in the Official Journal of the EU, with Member States required to transpose the directive into national law.
While many rules will come into effect only a few years from now, some will be effective immediately, such as Member States’ right to introduce mandatory domestic electronic invoicing without needing prior authorization from the EU.
12 February 2025 – European Parliament approves ViDA Proposal
The European Parliament has approved the VAT in the Digital Age (ViDA) proposal, bringing it one step closer to official adoption. The proposal will now head to the Council of the EU for final approval, marking a key step in the effort to modernize VAT systems throughout the European Union.
2024
5 November 2024 – Member States agree to adopt ViDA package
The European Parliament has approved the VAT in the Digital Age (ViDA) proposal, bringing it one step closer to official adoption. The proposal will now head to the Council of the EU for final approval, marking a key step in the effort to modernize VAT systems throughout the European Union.
The long-awaited VAT in the Digital Age (ViDA) proposal has been approved by Member States’ Economic and Finance Ministers. On 5 November 2024, during the Economic and Financial Affairs Council (ECOFIN) meeting, Member States unanimously agreed on adopting the ViDA package. This decision marks a major milestone in modernizing the VAT Directive, setting the stage for a more efficient and digital VAT system across the European Union.
Certain changes will take effect immediately once the package comes into force, while others will roll out in stages over the coming years.
The text will proceed to formal approval by the Parliament, after which it will be ready for official adoption.
1 November 2025 – New ViDA Proposal Set for ECOFIN Approval
The Council of the European Union has released a new proposal regarding the VAT in the Digital Age (ViDA) reform.
The proposal aims to modernise and streamline VAT systems across the EU, notably e-invoicing and Continuous Transaction Controls (CTC). Members States will review it on 5 November at the upcoming ECOFIN meeting. The main change in the new ViDA proposal concerns the dates when measures become effective. Deadlines have been postponed as a result of the setbacks ViDA has faced since its initial draft.
If approved, a series of changes will take place over time – some of which will take effect as soon as the Directive enters into force.
25 June 2024 – ViDA Rejected again
During the latest ECOFIN meeting on 21 June, Member States met to discuss if they could come to an agreement to implement the VAT in the Digital Age (ViDA) proposals. At the ECOFIN meeting in May, Estonia objected to the platform rules being proposed, instead requesting to make the new deemed supplier rules optional (an opt-in), allowing Member States to choose whether to implement them in their national VAT legislation or not.
In the meeting a new compromise text was proposed. The compromise text meant that there would be an opt in for the new deemed supplier rules but for SME businesses. Whilst 26 Member States and the commission came to an agreement on this, Estonia could not support the new compromise due to the fact there was no substantial changes since the last meeting and their objections remained. It will now be up to the Hungarian presidency to seek agreement on the proposals, during the second semester of 2024.
2023
November 2023 – Committee on Economic and Monetary Affairs proposes postponement of ViDA
The Committee on Economic and Monetary Affairs from the European Parliament has proposed to postpone most aspects of ViDA for at least one year. The committee cites ongoing delays in the legislative process as a reason for the postponement. The recommendation was decided on a nearly unanimous vote; no members voted against the measure.
If the Committee’s proposal is adopted as written, the revised launch dates for ViDA will be as follows:
E-Invoicing and Digital Reporting Requirements: Member States must implement administrative provisions for digital reporting requirements by January 1, 2029. The requirement for Member States to allow electronic invoicing, subject to common standards and without prior authorization from the tax authority, would take effect January 1, 2025.
Deemed Supplier Rules for Platforms: Member States must implement provisions to harmonize treatment of services facilitated by electronic platforms, and to impose deemed supplier rules for goods facilitated by electronic platforms, by January 1, 2026.
Single VAT Registration: Existing rules for VAT treatment of call-off stock would cease to apply as of December 31, 2025 [no change from original proposal]. Changes to Article 194 of the VAT Directive would take effect by January 1, 2026. Member States must implement provisions to expand the scope of non-Union and Union One-Stop Shop schemes by January 1, 2026.
2022
8 December 2022 – Commission adopts ViDA proposal and issues a follow-up feedback period
May 2022 – Feedback period ends
January 2022 – EU Commission proposes VAT in the Digital Age plan
Denmark E-invoicing
Denmark has mandated the use of electronic invoices, though not in all contexts, since 2005 – making it an early adopter of the technology. E-invoicing is required for suppliers of goods and services when conducting business with public entities (B2G).
There is no e-invoicing mandate for B2B transactions, however. This page provides an overview of the state of electronic invoicing in Denmark. Be sure to bookmark it to stay updated on future regulatory changes.
There is no e-invoicing mandate for B2B transactions in Denmark.
However, in May 2022, Denmark adopted the new Danish Bookkeeping under which Danish registered businesses or foreign companies with permanent establishments that have accounting obligations in Denmark are required to adopt digital bookkeeping systems compliant with the new regulations.
According to the new regulations, taxpayers in scope must use Digital Bookkeeping Systems capable of generating, receiving and storing electronic invoices in the Peppol BIS and OIOUBL (the Danish-specific version of the UBL) formats.
Businesses in Denmark can choose a digital bookkeeping system registered with the Danish Business Authority – which indicates it complies with the new Digital Bookkeeping Act). If a business opts to use a digital bookkeeping system that is not registered, it falls on them to ensure their systems meet the requirements according to the new Danish Bookkeeping Act.
The requirement to use compliant digital bookkeeping systems was introduced in a phased timeline:
2024 – Large taxpayers (defined as those who are required to submit annual financial statements) who choose to use a standard registered bookkeeping system (ERP) must ensure their bookkeeping system is certified by the Danish authorities
2025 – Large taxpayers (defined as those who are required to submit annual financial statements) choosing to use a specially designed or foreign bookkeeping systems must ensure that their system is compliant
2026 – Personally owned companies with an annual net turnover of more than DKK 300,000 in two consecutive years (e.g. 2024 and 2025) must ensure that their system is compliant
B2G e-invoicing in Denmark
In Denmark, sending and receiving electronic invoices is mandatory for B2G transactions. This means that suppliers of goods and services to public authorities and institutions must issue invoices electronically—either in the Peppol or national OIOUBL format.
The Danish government mandates using its NemHandel platform for sending and receiving e-invoices in a B2G context.
The use of Peppol in Denmark
Peppol is widespread in Denmark, serving as one of the two accepted means of formatting an electronic invoice. It’s said that 99% of B2G invoices in the country are electronic, and now the focus is improving the uptake of e-invoices in B2B transactions – which is not mandated.
The Danish Business Authority (ERST) is the nation’s Peppol Authority. This means it is responsible for registering companies that want to become a Peppol Access point or Service Metadata Provider (SMP), reporting, representing Denmark’s interests regarding Peppol and other related administrative efforts.
Follow Denmark’s e-invoicing journey with these key dates.
2005: Suppliers to public entities are required to issue invoices electronically
2017: Denmark integrates its e-invoicing system NemHandel with Peppol
18 April 2019: Public entities must be able to receive and process e-invoices to the European standard (EN-16931)
19 May 2022: Danish parliament passes law to introduce requirements for a digital bookkeeping system
1 July 2024 – The new Digital Bookkeeping Act requirements become applicable
Setting up e-invoicing in Denmark with Sovos
Complying with the tax requirements of one country can be tough; never mind multinational compliance everywhere you do business. Add e-invoicing requirements to that mix, and it can take up a lot of time and headspace in your organisation.
Sovos is your ideal compliance partner for wherever you do business: a single vendor for all of your tax requirements that frees you up to focus on what truly matters to you.
Contact us today to learn more about how Sovos can help.
Issuing electronic invoices is mandatory in Denmark for B2G transactions (suppliers of goods or services to public authorities and institutions), but there is no mandate for B2B e-invoicing in the country.
Digital bookkeeping systems must be able to issue, send, receive and store e-invoices in both the Peppol BIS and OIOUBL (the Danish-specific version of the UBL) formats.
This webinar will deepen your understanding of cross-border transactions within SAP. Whether you’re navigating the complexities of VAT or seeking to enhance SAP’s capabilities, this session will provide you with actionable insights and strategies to optimise your processes.
Join us on 30 April for our next VAT Snapshot webinar where we’ll be taking a look at the latest e-invoicing updates across 10 countries: Greece, France, Belgium, Malaysia, Philippines, Portugal, Angola, Israel, Slovenia and Croatia.
As governments worldwide continue to shift to Continuous Transaction Controls (CTC) systems, such as e-invoicing and real-time e-reporting, another trend organically unfolds as part of this move towards tax digitisation: pre-filled returns.
With access to real-time transactional level data – and other types of data, such as payroll, inventory and other accounting data transmitted at less regular intervals – tax authorities can facilitate other tax obligations with measures like prepopulating returns. This move ensures that the data submitted via CTC systems become the taxpayer’s single source of truth and highlights the importance of data quality.
Countries such as Chile – the cradle of e-invoicing – along with Indonesia, Spain and Portugal, have now been using pre-filled returns for several years. Many other countries have followed suit, with Greece being one of them.
Pre-filled VAT Returns in Greece: Overview
Greece made this significant step in 2022, introducing a new framework for pre-filled VAT returns based on data submitted through the myDATA platform. The measure aims to increase accuracy, transparency, and administrative efficiency for both businesses and tax authorities.
Greece has also made the pre-filing of income tax returns, namely the Statement of Financial Data from Business Activity (Form E3) based on myDATA, available.
As this framework evolved, Greece made another move. The country’s tax authorities set limits to the adjustments taxpayers could make to pre-filled returns, essentially locking the declarations to a certain extent. Since 2025, a zero-deviation limit has been reached for pre-filled VAT returns, while a more flexible cap is currently in place for Form E3. However, this is also expected to be gradually reduced over time.
What Are Pre-Filled VAT Returns?
Pre-filled VAT returns are VAT declarations that are automatically populated using data transmitted to the digital bookkeeping platform, myDATA. Rather than manually entering figures into the VAT return, taxpayers see their returns pre-filled with data based on their invoices and expense records submitted through CTC regimes.
Under this model, the VAT return becomes effectively “locked”. Taxpayers can no longer freely adjust revenue and expense fields. If discrepancies are identified, businesses must correct the data directly within myDATA to ensure the return reflects accurate information.
Key Regulatory Provisions
Ministerial Decision 1020/2024 is the regulation that outlines the rules governing how submitted myDATA data impacts pre-filled VAT returns, sets the limits on allowable deviations and the procedures for handling correlation difficulties.
The regulation introduced two core compliance rules:
Revenue Rule: VAT returns cannot report income that is less than what has been transmitted to myDATA. Overreporting is allowed.
Expense Rule: VAT returns cannot report expenses that exceed what has been transmitted to myDATA. Underreporting is allowed, including cases where the taxpayer voluntarily chooses not to deduct certain expenses.
Tolerable Deviation Thresholds
The regulation sets temporary thresholds for deviation between declared amounts and those submitted via myDATA to provide transitional relief from the revenue and expense rules. These are called tolerable deviation limits.
The initial rule allowed taxpayers to adjust their income and expenses by up to 30%. However, over time, the limits were gradually reduced. Since January 2025, the threshold has dropped to 0%, which means that there is no possibility of deviating from the amounts locked in the pre-filled return by myDATA under the revenue and expense rules.
Deadline for Corrections
One of the most important compliance aspects is the deadline for updating data in myDATA. Corrections must be made before the submission deadline of the VAT return for the relevant period. After that, the return is locked, and any subsequent changes would require the filing of an amended VAT return.
Pre-Filled Income Tax Returns
Since the 2023 tax year, Form E3 has been pre-filled based on data submitted to myDATA by taxpayers. However, from the 2024 tax year onwards, taxpayers may only modify these pre-filled amounts within certain limits.
According to new rules introduced in March 2025, a 30% deviation limit is established for revenue and expense data reported in Form E3, per tax year, in relation to the corresponding myDATA-reported values.
In addition to deviation limits, the new rules regulate aspects such as the classification of income and expenses, the mandatory reconciliation of reported data with myDATA records and the procedures for handling discrepancies in pre-filled amounts.
However, following the trend seen with VAT returns, deviation limits for Form E3 are expected to be gradually reduced until it is no longer possible to change the pre-filled amounts under the revenue and expense rules.
How to Ensure Compliance?
The move to pre-filled returns represents a broader shift toward real-time, data-driven compliance in Greece. While the framework introduces new responsibilities for taxpayers, it also simplifies the return process and reduces the risk of human error.
With tolerable margins eliminated for VAT returns – and further tightened for Form E3 – businesses should focus on proactive data management to fully benefit from the efficiencies of the new system.
To remain compliant and avoid discrepancies in their VAT returns, businesses operating in Greece should:
Ensure timely and accurate transmission of all invoices and expense data to myDATA.
Regularly reconcile internal accounting systems with myDATA entries.
Address any correlation difficulties early and document the reasons.
Stay informed about the eliminated and shrinking deviation thresholds and prepare for full alignment.
For businesses already familiar with digital reporting under myDATA, the transition should be smooth, but for others, now is the time to prepare.
In a previous blog, we provided an overview of the current and proposed natural disaster-related measurements in some European countries and Australia. In this blog, we will focus on the possible EU-level solution proposed by the European Central Bank (ECB) and the European Insurance and Occupational Pensions Authority (EIOPA) in their latest discussion paper, issued in December 2024.
The proposal, as was also in the case of their discussion paper from April 2023, focuses on the growing “insurance protection gap” in Europe. It highlights that Europe is the fastest-warming continent in the world. If we look back at only the last six months, there were at least three severe climate-related catastrophes in Europe: Portugal wildfires and the Spanish and the Czech Republic Floods.
Among other significant economic consequences of the increasing frequency and severity of natural catastrophes, we need to highlight the impact of these events on insurance businesses and indirectly on the taxation of the insurance premium amounts.
The paper summarises 12 existing national natural catastrophe insurance schemes which we are going to brief in our blog series – adding the current tax treatment of these schemes. In this blog, we provide an overview of the EU-level solutions as proposed by the paper and a summary of the approaches followed by the EU countries.
Proposal for the possible EU-level solution
A two-pillar solution was included in the referenced document. The two pillars are:
EU public-private reinsurance scheme: This would not substitute the national level reinsurance schemes, it would be additional. This scheme would be voluntary and financed by risk-based premium amounts. The aim of this pillar is to increase the insurance coverage of the natural catastrophe risk where insurance coverage is low.
EU fund for public disaster financing: This second pillar would be made compulsory and aims to finance rebuilding efforts after a high-loss natural disaster. Contributions from member states would finance this.
Both of these pillars could potentially affect the amount of tax payable by the insurance companies on the collected premium amounts. The first pillar might indirectly increase the tax amount levied on the reinsured premium amount, such as in the case of France CCR (Caisse Centrale de Réassurance), where IPT (and contributions to the Major Risk Prevention Fund) is due on the CATNAT premium. The second pillar may trigger newly introduced contributions that might be levied on the insurance premium amounts.
Summary of the national level approaches
The current national schemes aim to broaden insurance coverage. Some countries, like Italy most recently, make certain natural catastrophe risks such as earthquakes, floods and landslides compulsory to be insured by either or both entities or individuals.
In other cases, compulsory reinsurance involving public-private sector coordination exists. The most well-known reinsurance system exists in France, the so-called CCR. However, there is a reinsurance system in Iceland, where insurers collect CATNAT premium amounts and pay them towards NTI (Icelandic Natural Disaster Insurance).
It remains to be seen the extent to which the proposals are acted upon and the impact that they may have on premium taxation regimes in the EU. As it is such a significant topic in insurance currently, Sovos will be keeping a close eye on developments in this area.
Ireland E-invoicing
Ireland gave electronic invoicing the same legal weight as paper invoices in 2013. Since then, there have been no major developments regarding mandating e-invoicing in the business-to-business space.
Nevertheless, as part of the European Union, Ireland will soon need to work on implementing the European VAT in the Digital Age (ViDA) initiative, which aims to introduce mandatory e-invoicing and real-time reporting for cross-border transactions by July 2030.
This page details Ireland’s current stance on e-invoicing. Be sure to bookmark the page to stay in the know with any future developments.
There is no mandate for issuing and receiving electronic invoices for B2B transactions in Ireland.
Irish businesses can issue and receive electronic invoices and must consider the following legal aspects when implementing e-invoicing in the country:
Obtaining the consent of the buyer to send an electronic invoice.
Ensuring integrity and authenticity – any means are accepted, from internal process controls up to electronically signing the e-invoices.
Retention – e-invoices must be stored in such a way as to guarantee their integrity, authenticity and availability during the retention period. The retention period for electronic invoices is six years from invoice date.
The country’s tax authority is looking to modernise its VAT system. In late 2023, it launched a public consultation to understand how organisations feel about digitally transforming tax processes and proposed imposing a mandate for e-invoicing and real-time reporting when transacting domestically. The key driver of the consultation was the ViDA initiative.
Through the public consultation, the Irish tax authority managed to gather valuable insights from more than 1,000 businesses, aiming to use them in the design and implementation strategy phase.
With the final approval of ViDA Ireland will be able to impose mandatory e-invoicing in the country without the currently needed formal authorisation from the EU.
B2G e-invoicing in Ireland
While it is mandatory for central authorities, regional authorities and local authorities in Ireland to receive and process e-invoices, it is currently optional for suppliers to send electronic invoices.
The preferred national format for e-invoicing is Peppol BIS, but public administrations have defined their own format known as CIUS-CEFACT.
The Irish government encourages public sector organisations to utilise the Peppol framework when receiving e-invoices from suppliers.
The use of Peppol in Ireland
Ireland joined the OpenPeppol association on 18 January 2018.
The country’s Office of Government Procurement (OGP) operates the Irish Peppol Authority, which is responsible for registering companies wanting to become a Peppol Access Point or Service Metadata Publisher in Ireland.
1 January 2013: E-invoices are given same legal weight as paper invoices
18 April 2020: All public authorities can receive Peppol e-invoices via the Peppol eDelivery Network
13 October 2023: Ireland launches public consultation on e-invoicing and real-time reporting requirements
1 July 2030: Irish businesses need to comply with VAT in the Digital Age requirements (mandatory e-invoicing and e-reporting for cross-border B2B transactions).
Setting up e-invoicing in Ireland with Sovos
It seems inevitable that mandatory e-invoicing will arrive in Ireland. When that time comes, it’s important that your organisation is prepared for your new obligations.
Any new mandates only add to your compliance burden, with e-invoicing requirements being fragmented and unique to each country. Ensure you comply with your obligations, everywhere you do business, by working with Sovos.
Choosing Sovos means choosing a single vendor for all of your tax compliance needs.
Ireland does not mandate the use of electronic invoices. Public sector organisations must be able to receive e-invoices, but suppliers can choose whether or not to issue such documents electronically.
There are no officially announced dates for introducing mandatory e-invoicing or real-time reporting in Ireland. However, as part of the European Union, the country needs to implement the ViDA initiative by July 2030 and can start mandating e-invoicing as soon as ViDA is approved.
The United Arab Emirates (UAE) plans to introduce electronic invoicing requirements in 2026. The country’s project, known as the E-Billing System, includes plans to regulate both B2B and B2G transactions.
While the system has yet to be implemented, taxpayers should prepare for it so they can be compliant from day one. This page has the information you need to get started.
Compliance requirements for e-invoicing in the UAE
While no e-invoicing mandate currently exists in the United Arab Emirates, it does already permit the electronic exchange of business documents—so long as the medium and format are agreed upon by both the buyer and seller. To ensure the document’s authenticity and integrity, it must be stored in the same format in which the buyer issued it and signed with an e-signature.
Once a mandate is in place, taxpayers in the UAE will have to issue and receive electronic invoices through an Accredited Service Provider (ASP). According to the announced plan, only ASPs will be allowed to connect with the Tax Authority Platform to submit e-invoice data. Therefore, taxpayers will need to enter a commercial agreement with an ASP and integrate systems to allow for document transmission.
Electronic invoices will need to be sent in XML format, and the ASP will also share the invoice data with the Federal Tax Authority (FTA).
Timeline of e-invoicing adoption in the UAE
Here are the key dates in the United Arab Emirates’ e-invoicing journey so far:
11 July 2023: The Ministry of Finance (MoF) reveals five major digital transformation projects, including plans for an e-invoicing initiative known as the E-Billing System
14 February 2024: The Ministry of Finance (MoF) reveals plans for its E-Billing System
2 October 2024: MoF launches e-invoicing portal to provide information on upcoming requirements for businesses
30 October 2024: The UAE Official Gazette includes amendments to the national VAT law, driven by the upcoming e-invoice mandate in the country, which introduces e-invoicing considerations to the VAT law.
6 February 2025: MoF launches a public consultation on e-invoicing to gather feedback on proposed e-invoicing data requirements
The timeline announced for the roll-out of the UAE e-invoicing mandate is:
Q4 2024: Requirements and procedures for service providers to be developed
Q2 2025: E-invoicing legislation to be published
Q2 2026: The first phase of B2B and B2G requirements begins
Peppol e-invoicing in the UAE
The UAE’s Ministry of Finance has highlighted Peppol as a pillar of its e-invoicing framework.
Peppol is an international, EU-born protocol and framework that aids in simplifying cross-border and governmental trade. While its adoption is widespread across Europe, it is also standardising trading in countries such as Australia and Singapore.
The United Arab Emirates plans to implement a Five Corner Model for its Peppol implementation, and the nation’s Federal Tax Authority (FTA) will serve as a Peppol Access Point to enable taxpayers to exchange electronic invoices.
There are currently no strict requirements for electronic invoicing in the United Arab Emirates. Businesses can voluntarily send and receive e-invoices should both the buyer and seller agree on the medium and format.
The Electronic Transactions and Trust Services law in the United Arab Emirates was devised to regulate the validity of electronic documents. The law boosts the legal weight of digital signatures and has provisions for how electronic documents are sent, saved and stored.
The United Arab Emirates’ Ministry of Finance plans to publish the regulatory framework for the new e-invoicing system in Q2 2025. The first phase of mandating electronic invoicing for B2B and B2G transactions will start in Q2 2026.
Short for Standard Audit File for Tax, SAF-T is an XML-based file type used to exchange tax information electronically to tax authorities. The goal of the initiative is to enhance tax compliance and streamline data exchange between taxpayers and tax authorities.
SAF-T is an international standard used across Europe, including countries such as Poland, France, Germany, Romania, Lithuania, Norway and soon Bulgaria.
Different types of information typically have varying reporting requirements. For example, once implemented in Bulgaria, SAF-T rules will require the monthly filing of general ledger entries, purchase and sales invoices and payment records – while asset information must be submitted annually.
When to submit a SAF-T declaration in Bulgaria
SAF-T’s implementation in Bulgaria begins in January 2026. There will be three mandated SAF-T reports, all with different reporting cadences.
Monthly – submitted by 14th day of following month: General ledger, Accounts Payable and Receivable, Sales and purchase invoices
Annually – submitted by 30 June of following year: Fixed assets
On-demand: Inventory
Bulgaria SAF-T implementation timeline
Here are the key dates in Bulgaria’s SAF-T plans.
January 2026: SAF-T applies to large enterprises that either have:
Net sales revenue for 2023 exceeding BGN 300 million (approx. 150 million EUR)
Tax and social security contributions collected exceeding BGN 3.5 million
January 2027: SAF-T applies to large, medium and small enterprises that either have:
Net sales revenue for 2024 exceeding BGN 300 million (approx. 150 million EUR)
Tax and social security contributions collected exceeding BGN 3.5 million
January 2028: Large, medium and small enterprises that either have:
Net sales revenue for 2025 exceeding BGN 15 million (approx. 7.5 million EUR)
Tax and social security contributions collected exceeding BGN 1.5 million
January 2029 – SAF-T applies to all large, medium and small enterprises – regardless of additional conditions.
January 2030 – SAF-T also applies to micro-enterprises.
Note: There will be a six-month grace period for SAF-T reporting, and taxpayers can submit corrections to submitted files within six months without being penalised by the tax authorities.
Implementing SAF-T as a business
Complying with your tax obligations is vital. In the coming years, SAF-T will serve as another requirement for Bulgarian taxpayers, providing deadlines for the accurate reporting of important data. This will only add to your compliance workload.
Sovos SAF-T solutions can help your organisation to spend less time on compliance and more on growing your business. Automate your preparation process to drive efficiency and ensure accuracy, providing peace of mind that you will avoid potential fines and penalties.
SAF-T is not mandatory in Bulgaria, though its legal implementation begins in 2026 for qualifying large businesses. It will be obligatory for businesses of all sizes in Bulgaria from January 2030.
From January 2026, large enterprises will need to file SAF-T reports if their net sales revenue for 2023 exceeds BGN 300 million or tax and social security contributions collected exceed BGN 3.5 million.
From January 2027, large, medium and small enterprises will have to file SAF-T reports if their net sales revenue for 2023 exceeds BGN 300 million or tax and social security contributions collected exceed BGN 3.5 million.
From January 2028, large, medium and small enterprises must comply with SAF-T requirements if their net sales revenue for 2025 exceeds BGN 15 million or tax and social security contributions collected exceed BGN 1.5 million.
From January 2029, Bulgaria’s SAF-T obligation will expand to include all large, medium and small enterprises. This will grow to include micro-enterprises in January 2030.
From 2026, applicable taxpayers in Bulgaria will have to submit SAF-T reports as per the following:
General ledgers, Accounts Payable Receivable, and sales and purchase invoices must be submitted monthly – specifically by the 14th day of the following month.
Fixed assets must be reported annually – specifically by the 30 June of the following year.
Inventory reports must be submitted whenever requested – this is an on-demand reporting process.
Join Sovos at the 18th Group Indirect Tax Exchange and gain insights from our expert on the Industry Adoption of E-Invoices and E-Reporting Challenges. Stay ahead of the latest e-Invoicing conversations and make the most of this premier conference and networking event. Reserve your ticket today!
Discover Romania’s recent SAF-T implementation and its complexities with E-Reporting, E-Invoicing, and E-Transport. Learn from established systems in Portugal, Denmark and Norway, and prepare for upcoming SAF-T rollouts in Bulgaria and Hungary, as well as new E-Invoicing mandates across the EU.
Join us for an in-depth webinar designed to help event organisers navigate the complexities of VAT compliance for international events. Discover essential steps for handling cross-border VAT, understand Place of Supply rules for physical and virtual events (including the new 2025 updates) and learn how to avoid common VAT risks.
Our VAT Snapshot series aims to provide you with information to untangle the complex web of tax obligations created by multi-national trading, helping you stay compliant with the latest tax requirements across Europe. In our first webinar of 2025, we’ll discuss the latest e-invoicing updates in Poland, Estonia, Greece and Portugal.
February 10 to 12, 2025 in Dubai
The Middle East and Africa are facing a rapidly evolving landscape for E-Invoicing and VAT reporting. We follow this development and continue the successful first two editions of the E-Invoicing Exchange Summit and proudly announce the 3rd edition to be held in Dubai from February 10 to 12, 2025.
On the pre-conference day, Monday, February 10, you will have the opportunity to start the E-Invoicing Exchange Summit by attending the workshop “GENA Academy Essentials: Everything You Always Wanted to Know About E-Invoicing, but Were Afraid to Ask”. Furthermore, a great networking opportunity awaits you with the Icebreaker Reception in the early evening. The conference itself will take place on Tuesday and Wednesday, February 11 and 12, including the Networking Dinner on Tuesday evening.
Insightful presentations and interactive roundtable sessions on
Mastering E-Invoicing Now: Actionable Steps for Compliance and Efficiency
Streamlining Compliance for UAE E-Invoicing with SAP Document and Reporting Compliance
Convergence of Digital Real-Time Controls & Business Automation
Managing Tax Compliance Risks in the Middle East Post-E-Invoicing
Big Data vs Big Brother – How Mirror Visibility Drives Indirect Tax Consolidation
Global and Regional Compliance Update + Implementation and Adoption Progress Reports from around the Globe
