The recent Ministerial Decision (No. Α 1138 / 2020) clarifies the scope of application, the exceptions, the data transmitted, the time of transmission, the specific obligations of the entities, the procedure, as well as any other necessary issue regarding the implementation of the provisions of article 15A of Law 4174/2013 (A '170) regarding the transfer of documents to The Independent Authority of Public Revenue (“I.A.P.R”-"A.A.D.E.").
Ι. SCOPE OF APPLICATION AND EXCEPTIONS
Within the scope of application are all the entities of Article 1 of Law 4308/2014 (Α΄251), regardless of the size and manner of issuance and conservation of their accounting records, which are obliged to transmit the following:
GENERALL DATA TRANSFER |
|
|
|
It is clarified that the following do not fall within the scope of the application:
EXCEPTIONS |
|
|
ΙΙ. DATA TRANSMISSION
For the uniform application of the procedure, the documents have been standardized, and the data of the documents, and the registrations that will be forwarded to The Independent Authority of Public Revenue (“I.A.P.R”-"A.A.D.E.") is described in detail, in the following table:
DOCUMENT TYPE/REGISTRATION | DATA TRANSMISSION |
Invoices |
|
Retail Sales Records |
|
Other Registrations |
|
ΙΙΙ. WAYS AND PROCEDURE OF TRANSMISSION
The data mentioned in the previous paragraph is transmitted to the electronic platform myDATA, under summary form, without an analytical distinction between items and records. The data of the accounting records is transmitted per transaction characterization by their issuer and in any case per tax rate and fee, regardless of their value and method of issuance (computerized or handwritten).
Exceptionally, the specified data is transmitted by the recipient of the goods or services (domestic entity) in the following cases:
- Transactions with non-liable entities abroad, such as intra-community acquisitions, imports from third countries and receives of services (intra-community, third countries etc.)
- Receipt of retail documents domestic or foreign, such as co-proprietor charges, subscriptions, retail foreign transactions
- Transactions related to the sale of electricity (only PPC-“DEI”) and water (“E.Y.D.A.P.”, municipal enterprises, etc.)
- Transactions with credit institutions
- Documents of payment of contributions to insurance funds, such as those issued by Social Security Institution (“E.F.K.A”) and
- Documents which do not comply with the transmission of the defined data by the issuer.
In case the accounting records (invoices, retail sales records) issued by the recipient of the goods or the services (self-pricing) or by a third party by name and on behalf of the seller (pricing-assignment) the specified data is transmitted by the recipient or by the third party which has been assigned the pricing respectively, provided that there is a relevant reference to the prerequisite agreement (par. 5, Article 8 of Law 4308/2014).
The transmission of the data to The Independent Authority of Public Revenue (“I.A.P.R”-"A.A.D.E."), defined by the aforementioned Ministerial Decision, is carried out by the liable entities electronically in the following ways:
WAYS OF TRANSMISSION |
|
The specified data is transmitted as the case may be, either:
- From the entity itself or an authorized accountant,
- From the recipient during the self-invoicing process,
- From the Service Provider of Electronic Invoicing,
- From the third party in case of invoicing-assignment
IV. TIME OF TRANSMISSION AND DOCUMENT’S BRIEFING
Real Time |
|
20th day of the next month |
|
Until the submission of Income Tax Return Statement | Revenues-Expenses settlement registrations |
Until the submission of VAT statement |
|
Until the submission of WHT taxes | Payroll registrations |
As the date of transmission and successful electronic registration in the system of The Independent Authority of Public Revenue (“I.A.P.R”-"A.A.D.E."), of the data specified herein, the date of issuance of the Unique Registration Number (“M.AR.K.”), is obtained. For the documents that are transmitted through a direct connection of the approved cash registers (“ΦΗΜ”) with The Independent Authority of Public Revenue (“I.A.P.R”-"A.A.D.E.") the date of transfer and successful registration, results from the information system of the approved cash registers (“ΦΗΜ”).
V. TRANSACTIONS CHARACTERIZATION AND SPECIAL OBLIGATIONS OF THE ENTITIES
Essentially, the time of transaction characterization, is the same as the time of income documents transmission except for the case of the provision of electronic pricing services, that the time of transmission of the transaction revenue characterization can be carried out by the liable companies later and until the 20th day of the next month from the issuance.
In the case of characterization of transaction expenses, the transfer of data by the liable Companies is carried out until the submission of the relevant statement concerning.
VI. COMMENCEMENT OF PRODUCTIVE FUNCTION OF THE PLATFORM AND RECEPTION OF THE DATA TRANSMITTED
The dates of transmission of the information are presented in the following table:
Revenues | Revenues | ||
Businesses - Invoices | Dates | Businesses - Invoices | Dates |
Businesses using electronic invoicing | 20/07/2020 | Purchase ledgers issued from 01/10/2020 and forward | 01/10/2020 |
Businesses that use handwritten invoicing or invoicing via ERP | 01/10/2020 | Purchase ledgers issued from 01.2020 to 09.2020 | Until 28/02/2021 |
Businesses not obliged to use the approved cash registers (“ΦΗΜ”) | 01/01/2021 | ||
Businesses obliged to use the approved cash registers (“ΦΗΜ”) | 01/10/2020 | Payroll Registrations from 01/01/2020 to 30/09/2020 | Until 31/12/2020 |
Sales ledgers 2020 | Until 31/12/2020 |