Taxpayers still have time to find alternative solutions for online invoicing! - Mazars Tax Newsletter 2018/15

The Tax Authority has published on their homepage for the online invoicing that those enterprises, which are not ready with the implementation of the necessary IT background on the 1^st July, may provide the invoices’ data to the Tax Authority’s server retrospectively, until the end of July, without any penalty. So the good news is that the July invoices’ data can be filed retrospectively. However, the taxpayers must send the invoices’ data on a real time basis from 1^st August.

The above moratorium gives the chance to those taxpayers, who are not ready at the moment. But this also gives the chance to those taxpayers, who will be not ready even after 1^st August to find alternative solutions for the online invoicing. But what are the alternative options?

• Instead of their own invoicing software, they can use NAV’s Online Invoicing program, which will be available free of charge. This will primarily satisfy the general invoicing needs of micro and small-sized enterprises.
• As a second option, they can obtain a third-party software or subscribe to a web-based invoicing service which can satisfy the data supply requirements. In other words, the currently used invoicing system can be replaced, relatively quickly and at not too high costs. However, such an inexpensive, web-based invoicing solution cannot easily be inserted into the integrated enterprise resource planning and accounting processes. Therefore, certain companies are likely to engage in “shadow invoicing,” the essence of which is that they issue an invoice using some external software, but only for the purpose of satisfying the requirements of NAV and to ensure that the data supply obligation is performed, while in a parallel way also generating another, “in house” invoice for accounting purposes, using their integrated system. This entails the danger that the tax authority may object to the double invoicing of the same transaction, especially if they send the latter, in house invoice to their customer. It is also important to call attention to the fact that, theoretically, penalties may also be imposed on taxpayers who refer to technical problems on a continuous basis and upload their invoices manually because their invoicing software cannot really perform the data supply function.
• For all practical purposes, the most viable solution may be for the company to “outsource” their invoicing to a tax consultant or accounting service provider that is fully prepared for online invoicing. The VAT Act provides an opportunity for the above: it is possible to give a written authorisation to another person to issue the invoices. This is a lawful and relatively quick solution – even only for a transitory period, until the company’s own system is finished – to the problem.

If you have any questions on the above, please do not hesitate to ask your Mazars contact person.