Have you already prepared for online invoicing?- 3. part- Tax newsletter 2018/ 10

In our earlier newsletters, we have provided information on the most important rules pertaining to the real-time data supply obligation and the fundamental operation of the system. In this newsletter, we would like to call attention to the fact that it is of utmost importance to monitor and check what data we actually supply to the Tax Authority.

Ultimately, it is the VAT Act that determines what data are required to be included in the invoice. Accordingly, the Tax Authority may only require such data supply obligation in its online system that is in line with the requirements of the VAT Act. At the same time, the user manual of the real-time data supply system and the explanations in this document – even though it is very useful for the developers – should be treated with considerations.

According to the user manual issued by the Tax Authority, certain fields are mandatory elements of the data supply. The examples of the manual include the gross amount payable as a required field; however, this is not a mandatory content element of invoices as per the VAT Act. In a similar example, according to the description of the XSD schema definition, the line item is not a mandatory content element in the course of the data supply; however, this is only true when we issue a corrective note that does not modify the item line itself.

With the above short examples, we also wanted to point out that we cannot leave the IT team to develop without the participation of a taxation expert person, since the taxation aspects must be also taken into consideration in the development process as much as the interface specifications. The developers need the assistance of an expert proficient in taxation issues in order to ensure that that data is supplied properly after 1^st July 2018.

Finally, it is important to mention the problem that in many cases invoicing software even today do not comply with the requirements of the VAT Act and the relevant government decrees, resulting in accounting documents prepared with incorrect form or content. We suggest, therefore, that before supplying the Tax Authority with data, from which it can be easily determined that the invoicing software already works incorrectly, the preparation should be started by making the existing invoicing software and invoice layout compliant with the provisions of law in effect currently.

If you have questions any questions concerning the rules of online invoicing, or need technical assistance in the course of the development efforts, your Mazars contact will be pleased to help.