Compliance Updates

Extension of acceptance of PDF formats

The Secretary of Tax Affairs stated in November 2020, that PDF invoices will still be deemed as electronic for tax and legal purposes, until March 2021.

This has now been extended from 31 March 2021 to 30 June 2021.

Mandatory transmission of tax documents’ data to myDATA platform postponed to July 1st, 2021

The start date for the mandatory transmission of tax documents’ date has already been postponed several times, with the last postponement to 1 July 2021.
It is important to note than none of the postponements left taxpayers ‘off the hook’ completely as the Greek tax office (AADE) considers the delays as grace period. The data that was generated in the grace period must still be submitted to the authorities through the myDATA platform by 31 October 2021.

6% Reduced VAT Rate for Streaming Theatrical Performances and Concerts

The Greek Public Revenue Authority (AADE) has recently published a Circular regarding the reduced VAT rate for tickets for streaming theatrical performances and concerts.
As of 11 March 2021, the 6% reduced VAT rate will apply for tickets for access to live streaming of such events. The new rate will apply for as long as the measure suspending public attendance to such events is in effect.

Argentina mandates QR codes on e-invoices

The Argentine tax authority (AFIP) has issued a general resolution (resolución general 4892/2020) which mandates the obligation to include a quick response QR code in e-invoices. This QR code should codify the identification of the parties and other essential data of the invoice (date of issue, total amount, currency).
Starting from 1 June 2021, all VAT taxpayers are required to implement QR codes in their e-invoices.

Paraguay plans e-invoicing pilot programme

Paraguay has started The Sistema Nacional de Facturación Electronica Nacional “SIFEN” (National E-Invoice System) in 2018, it was settled as a three-stage project divided as follow:
• 1- Pilot Plan: in which 14th local companies where selected and became the first e-invoices issuers.
• 2- Voluntary Adhesion: started in 2020 and to the date there are almost 200 companies participating in the programme. The companies submit an application to be part of the programme and where selected by the Tax Authorities.
• 3- Generalization: it’s set to start after the finish of stage 2, Tax Authorities will select companies to be included in the SIFEN till all the taxpayers are part of the programme.
Currently Paraguay is at the last part of the stage 2 which implies that the 200 companies have to finish their private systems develops on the last version of the Manual Tecnico V. 150 (Technic Manual) and be ready to operate with e-invoice. It is not required yet that those companies stop using regular invoices.
The pilot programme will test the functionality of a new tool called “E-KUATIA”. This is a free e-invoice tool aimed at physical persons and one-person companies.
More information on the E-KUATIA e-invoicing tool is available on the following website: https://ekuatia.set.gov.py/portal/ekuatia

Vendor registration to open for ‘Qualified Invoice Retention System’ from 1st October 2021

Japan will introduce a new qualified invoice regime for Japanese Consumption Tax (JCT) effective 1 October 2023. Under the current ‘Transitional Invoice Retention System’ (effective since 1 October 2019), in order to claim a JCT input credit, taxpayers are required to comply with certain bookkeeping and invoice retention requirements. This includes the recording of general information, such as the name of the vendor, date of transaction, consideration paid for transactions, etc.
Under the ‘Qualified Invoice Retention System’ (effective 1 October 2023), in addition to similar bookkeeping and invoice retention requirements, a taxpayer will only be able to claim an input JCT credit from a JCT-registered vendor.
To become a JCT-registered vendor and issue a qualified invoice, vendors must submit the appropriate application to the National Tax Agency (NTA). JCT exempt entities will be ineligible to become a registered vendor.
The application for this registration will begin on October 1, 2021, and in order to become a registrant by 1 October 2023, the vendor should file the application with the relevant tax office no later than 31 March 2023. The NTA will publish a list of registered entities on its website.

VAT Executive Regulations published

The VAT Executive Regulations have been issued by the Oman Tax Authority ( Decision 53 of 2021 (in Arabic)) on 14 March 2021 – this will allow companies to properly prepare for the introduction of VAT in Oman, starting from 16 April 2021.
See here for further details.

Enhancements to e-invoicing system

Tax authorities in Indonesia previously released a new version of the electronic-based invoice invoice (Faktur Pajak or ‘FP’). This includes a pre-populated feature to ease taxpayers’ workflow in carrying out VAT compliance. The pre-populated feature under eFaktur version 3.0 covers input VAT from normal VAT Invoices and import declaration documents. These documents will automatically appear in the eFaktur system under the respective tax period. Taxpayers are no longer required to input and validate the information manually.

Public consultation e-Invoicing B2B

Slovakia’s e-invoicing initiative is currently in the process of consultations by the authorities of the Slovak Financial Directorate. Based on the authorities’ preliminary statements about e-invoicing, Slovakia is planning to introduce real-time invoice reporting (RTIR) which should be mandatory for all transactions over time. The aim of this initiative is to reduce administrative burdens on the side of tax subjects (e.g. to reduce obligatory VAT reporting) and to obtain real-time invoicing data on the side of tax authorities and use it for tax control purposes.
Mandatory e-invoicing will be introduced gradually. The first phase will (probably during 2021) cover G2G and B2G transactions. In a later stage, (the expectation is in 2022) for B2B and B2C transactions will come under the legislation.
As we have seen in other countries, applying mandatory e-invoicing into practice requires a significant amount of new regulation and legislation.

Draft resolution published by GAZT: open for public consultation

We have now been aware for some time that KSA is moving towards mandatory e-invoicing.

On 18 March 2021, GAZT published a draft resolution – again for public consultation – on the requirements. The draft resolution includes technical specifications and procedures for implementing the provisions of the E-Invoicing Regulation. The resolution aims to specify the business and technical requirements that will need to be adhered to as Saudi Arabia moves toward e-invoicing.

GAZT encourages businesses start assessing how the e-invoicing regulations will impact their systems and processes and commence the planning work to successfully implement e-invoicing by the deadline of December 4^th, 2021.

An English translation of the draft resolution can be found here.

India extends the scope of the invoice reporting mandate from April 1, 2021

The Indian Central Board of Indirect Taxes and Customs (CBIC) has changed the revenue threshold that determines whether companies are required to report invoice data to the Invoice Registration Portal (IRP).

Via Notification No. 05/2021–Central Tax, the Central Board has lowered the threshold to Rs 50 Cr ($6.8m). The revenue threshold applies to aggregated revenues on PAN-level (Permanent Account Number) and will therefore apply to all GSTINs under the Permanent Account Number.

The change will be effective from April 1, 2021.

The announcement has been published in the Gazette of India on 8 March 2021: http://egazette.nic.in/WriteReadData/2021/225713.pdf

China expands its e-invoicing pilot program

In December, China’s State Taxation Administration (STA) announced further expansion of the trial programme (Pilot) to 38 regions in the country. The pilot enables specific Chinese taxpayers to issue VAT special electronic invoices on voluntary basis. The pilot project started in September 2020.

Read more

Poland and Brexit - waiver of requirement of fiscal representative for the UK and Norway 

The Polish Ministry of Finance published draft tax legislation on 12th February, under which UK and Norwegian based companies will not be obliged to appoint fiscal representation in Poland.

This important decision is mainly due to adequate agreements for mutual assistance being in place between countries. These agreements arrange administrative cooperation and collaboration to fight against VAT fraud. The legislation comes into force retrospectively with an effective date of January 1, 2021.

Fast progress on “structured invoices’ programme

For some time now, Poland has been stating that it would implement their continuous tax controls regulation ahead of France. They seem to be making good progress.

The Polish Government Legislation Centre has published a draft law amending the VAT Act, introducing a model of ‘structured invoices’ to the local VAT system. The draft law is available for public consultation for a very short period in February. The expectation is that the law will come into force by October 1, 2021. It should be noted that, initially, invoice issuance and reception via the national e-invoicing platform (Krajowy System e-Faktur (KSeF) or National e-Invoicing System (NeIS)), will be voluntary and businesses can continue to use current formats, including paper, PDF and other e-invoicing formats. However, the government will reward early adapted with faster VAT returns. The system is expected to become mandatory by 2023.

NOTE: The Polish KSeF system strongly resembles the Italian Sistema di Interscambio – invoice issuance and reception will take place in the platform and an archiving function is available from the system.

Note that the draft law leaves room for more detailed regulation to be added by ministerial decree.

KSA publishes its final e-invoicing regulation

As we reported before, Saudi Arabia is well on its way to mandatory electronic invoicing, only 4 years after the introduction of VAT in the Kingdom.

In autumn of 2020, KSA completed their public consultation regarding the planned e-invoicing regulation, followed by the approval of the GAZT board of directors of the final version of the regulations. This final version has been published in the official Saudi gazette on 4 December 2020 and entered into force immediately on the same day it was published. The regulations contain the framework of the e-invoicing mechanism GAZT is anticipating to apply and the expectation is that businesses in scope of the regulation will be able to comply by 4 December 2021.

While the timeline is very tight, not all details are clear, and it is expected that further details will follow prior to the effective date to help taxpayers comply with the new rules.

This is a tight timeline and businesses in the Kingdom should begin their implementations early in 2021. We see this as a unique opportunity for organisations to leverage digital technology and benefit from more streamlined tax operations.

Electronic Fiscal Receipting and Invoicing requirements

On 1 January 2021, the Electronic Fiscal Receipting and Invoicing Solution (EFRIS) entered into force in Uganda. Businesses use EFRIS to their issuance of receipts and invoices for tax purposes.

As of 1 January 2021, a person who conducts business and is registered for VAT purposes is required to issue an e-invoice or receipt for any sales transaction regardless of whether the sales transaction is subject to VAT at a standard rate, zero rate or VAT exempt.

Slovakia announces an e-invoicing/real-time reporting system

In a recent press release the Slovakian Tax authorities pointed at a new draft law on sending data to the Financial Administration. Please follow the link here for the full text.

The intention of the draft law is to introduce the obligation for all business entities to issue an invoice for each business transaction within a certain period of time. At the same time, invoice pre-clearance is also foreseen: the obligation to send specific invoice data to the Financial Administration before the final version of the invoice is prepared and sent to the buyer. Taxpayers can fulfil their invoice reporting obligations in various ways: using an e-invoicing service provider; directly from their accounting software/ERP using a certified communication method or using a free government portal. There will also be reporting obligations on the buyer.

Currently there is no more information or technical details available. We will continue to monitor Slovakia’s progress and report these in our upcoming e-invoicing updates.

Temporary introduction of 0% VAT rate on vaccines

From Jan 1, 2021 until Dec 31, 2022 a 0% VAT rate will be applicable on vaccines.

Extension of reduced VAT rate 

Greece has confirmed a further extension of the reduced VAT rate of 13% for cinemas, drinks and catering services, public transport and packaged holidays until 31 October 2021.

GST changes in Singapore Budget 2021

The Singaporean government has decided that the planned GST increase from 7% to 9% will not take place in 2021. The Finance Minister has however emphasised base GST will need to be raised at some point between 2022 and 2025. This is mainly to support government revenue to fund rising healthcare expenditure.