B2G e-invoicing delay for small / medium enterprises

Further to Law Decree 42-A/2022, dated 30 June 2022, the proposed extension of the B2G mandate to small / medium enterprises (SMEs) has once again been delayed and is now expected to be implemented on 1st January 2023.

This is synonymous with the further extension of PDFs being accepted as an e-invoice until 1st January 2023, underlining the Portuguese Tax Authorities’ intention to consolidate and expand the scope of their fiscal measures.

Go-live of e-invoicing pilot for 100 large taxpayers

The implementation of e-invoicing in the Philippines has now gone live as planned on 1st July 2022. Initially, the mandate will cover 100 large taxpayers selected by BIR (Bureau of Internal Revenue) including:  

  1. Taxpayers engaged in the export of goods and services.  
  1. Taxpayers engaged in electronic commerce (e-commerce);  
  1. Taxpayers under the Large Taxpayers Service (LTS). 

As of 1st July 2022, selected taxpayers are legally required to issue e-invoices/e-receipts and transmit them to the EIS portal in real time, or within 3 days from the date of the transaction. The document must be transmitted in the format of JSON (JavaScript Object Notation). In the event that sales data are delayed, late, or not transmitted to ElS, a penalty shall be imposed. 

To issue/transmit sales data, taxpayers must develop a Sales Data Transmission System and obtain certification from BIR. A Permit to Transmit (PTT) must also be applied by the taxpayer before the ElS can receive sales data. 

BIR expects to gradually roll out the mandate to all taxpayers in 2023. In the meantime, taxpayers who are not covered by the mandate yet may opt to use electronic receipts or sales/commercial invoices in lieu of manual receipts and invoices.  

E-invoicing threshold to be further lowered from 1st October 2022

With the recent issuance of Notification No.17 2022, the threshold for mandatory e-invoicing will be further lowered to ₹10 crore (from ₹20 crore) on October 1, 2022. From this date, GST registered businesses with annual turnover of ₹10 crore or more must issue e-invoices for B2B transactions.

Further, Vivek Johri, the Chairman of the Central Board of Indirect Taxes and Customs (CBIC), has made the following statement: “We started with a very high threshold and soon we are going to have all taxpayers with an annual turnover of more than ₹5 crore having to generate e-invoices for their B2B part of business.” According to Mr Johri, the ₹5 crore threshold will likely to be introduced in the course of 2023.

The India government has implemented e-invoicing in a phased manner ensuring minimum burden on the taxpayer community, the recent measures on threshold cuts will improve tax compliance and move closer to making e-invoicing mandatory for all GST taxpayers eventually. Tungsten has been supporting the e-invoicing mandate since its introduction in 2020 and is prepared to meet this new threshold requirement.

Looking to implement e-invoicing gradually in 2023

According to the 2023 Pre-Budget statement, the Malaysian Ministry of Finance intends to implement e-invoicing as a means of increasing tax revenue and digitalizing tax administration in the country.

The e-invoicing initiative will also support the use of the TIN (Tax Identification Number) in Malaysia, which will be implemented in 2022. The Statement points out that e-invoicing will be introduced in stages from 2023. However, no specific timeline has been mentioned.

We are closely monitoring the developments in Malaysia and will continue to keep our customers informed.

New e-invoicing phase 2 requirements

From 1st January 2023, Saudi Arabia will require that Business-to-Business (B2B) and Business-to-Government (B2G) transactions be cleared with the Saudi government (ZATCA) before these can be sent to the buyer.

Tungsten Network is committed to supporting the upcoming e-invoicing mandate in Saudi Arabia and has produced this FAQ that provides insightful information on the requirements and how they would impact your invoice processing. It also presents how Tungsten’s services can assist you in ensuring a seamless transition.

B2G mandatory e-invoicing

Luxembourg is following the lead of e-invoicing developments in neighbouring countries Belgium and the Netherlands, by mandating B2G e-invoicing in the country.

E-invoicing is projected to take place in a phased implementation in line with the following timeframes:

  • 18 May 2022: Large companies in Luxembourg will be required to send e-invoices to the public authorities
  • 18 October 2022: medium-sized taxpayers will follow suit
  • 15 March 2023: small and new businesses will complete the transition to e-invoicing

Luxembourg will follow the path of many European countries by using the PEPPOL Network for B2G e-invoicing. This means that invoices will be converted into the standard PEPPOL BIS 3.0 format and transferred through the PEPPOL channel (AS4). It will also require companies to be connected to a PEPPOL Access Point, to facilitate connection with other participants on the PEPPOL Network.

The move to e-invoicing will provide greater automation of the e-invoicing process, leading to reduced errors and cost-saving.

Tungsten Network is compliant in Luxembourg and will follow e-invoicing developments in the country.

Potential e-invoicing mandate

The adoption of e-invoicing across Europe is gaining some momentum. There are indications that Bulgaria has been influenced by countries in close proximity and intends to introduce an e-invoicing mandate for B2B transactions.

Authorities in Bulgaria are holding public consultations, and e-invoicing is being considered amongst other digital VAT-related incentives.

At the moment, the proposal to introduce e-invoicing has not yet been crafted into law. However, this does demonstrate the inclination of countries to digitalise their tax-related processes for a more automated and efficient framework of their fiscal operations.

Tungsten Network is compliant in Bulgaria, and we will closely monitor growing e-invoicing impetus in the country.

E-invoicing mandate delay

Last month we communicated around the derogation granted to Poland by the European commission to mandate e-invoicing in the country. We expected the Polish mandate to be enforced through the course of 2023.

The European Council has revised the date from which the derogation applies to 1st January 2024. This was approved by the European Council on 17 June 2022. This means Poland, at the earliest, can start mandating e-invoicing in the country from 1st January 2024. The derogation is effective until 31 March 2026.

The legislation has now been published in the official Journal of the EU Union and the derogation is not legally binding.

Tungsten Network is preparing to be ready for the Polish mandate and we will continue to update you on our progress.

PEPPOL framework on the “Qualified Invoice system”

We previously wrote about the upcoming “Qualified Invoice system” for Japanese Consumption Tax (JCT), in which taxpayers are only able to claim input VAT from JCT registered vendors. All Japanese vendors intending to issue e-invoices must register with their local tax office before 31 March 2023.

In addition to this, the Japanese government is working on implementing the “Qualified Invoice” system using Peppol standards. Peppol is a common framework for trading partners to exchange standards-based electronic documents over the Peppol network.

EIPA (E-Invoice Promotion Association), established in July 2020, is the dedicated organization responsible for developing and building a simple-to-use electronic invoicing system for Japanese companies. The “Qualified Invoice” System will launch in October 2023, but businesses are encouraged to begin using Peppol-compliant e-invoicing software by October 2022.

ZATCA to subsidize purchase of e-invoicing software

The Kingdom of Saudi Arabia has mandated e-invoicing Phase One (Generation Phase) since 4 December 2021, and Phase Two (Integration Phase) will come into effect on 1 January 2023. When the integration phase kicks off, taxpayers will be required to exchange their invoice data with the tax authority – ZATCA.

ZATCA has announced that it will offer to subsidize the purchase of e-invoicing software. In order to submit a request, taxpayers must provide certain detailed information and the invoice they received from the e-invoicing service provider. The “E-invoicing Subsidy Request” form can be accessed on the taxpayer portal.

Saudi Arabia initiate procedures for Phase 2 implementation

As per the announcement on ZATCA’s portal dated 24 June 2022, implementation of Phase Two (Integration Phase) of the E-invoicing project will begin on 1st January 2023 with selected taxpayers in the first wave. Resident companies with over SAR3 billion in taxable turnover in 2021 will be included in the first wave and should comply with the Phase 2 requirements.

ZATCA will begin to inform and communicate with the targeted taxpayers to complete procedures for implementing Phase Two (Integration Phase) of E-invoicing.

Requirement for certified software

Many countries require businesses to use certified software to produce the legal invoice in a country. Portugal is a good example.

This means that Tungsten has had to adopt its ‘standard’ offering to customers. We do not create the legal invoice on behalf of suppliers in Portugal, but rather ask the suppliers to attach the legal invoice to our system.

Similarly, Spain has announced that as of 1st January 2024, only state or VERI*FACTU approved invoicing software may be used to prepare and submit invoices.

Tungsten will need to assess the requirements the Spanish government has proposed for potential certified software providers from 1st January 2024, when the changes are expected to take place. Tungsten Network is analysing these requirements and seeing how we can best support our Spanish market considering these new requirements.

Tungsten Network is aware of the growing traction of e-invoicing in Spain. We are closely monitoring e-invoicing developments in the country.

New guidelines published for the B2G sector

The Irish government is actively promoting e-invoicing throughout the country to raise greater awareness around e-invoicing.

To this effect, it has published guidelines which assist suppliers in sending invoices to the public sector.

Ireland has recently stated that it will draw inspiration from the e-invoicing models in other countries as a basis for its own e-invoicing model. It will be interesting to see the developing e-invoicing landscape and the appetite for e-invoicing in the country further to this campaign driving greater recognition of the sector.

Expansion of scope of e-invoicing mandate

We have published extensive updates on the obligation for taxpayers to report cross-border invoices to the Sistema di Intercambio (SdI), which becomes mandatory from 1st July 2022.

The Draft Law Decree PNRR 2, the National Recovery and Resilience Plan, was approved on 13 April 2022.

This has expanded the scope of the taxpayers now obligated to report their cross-border invoices to the SdI from 1st July 2022.

Amongst the groups now subject to the e-reporting of cross-border invoices are:

  • Taxpayers who adopt the flat rate regime
  • Amateur sports associations and third sector entities with a revenue of up to 65,000 Euros