The key question will be whether the DRR and e-invoicing measures go far enough to reign in the disparate measures either already implemented by certain Member States, or scheduled for implementation, prior to these proposals coming into effect.
1. B2B crossborder transactions e-invoices within 2 days > sooner invoicing + cashflow impact
2. E-invoicing to cover B2B purchase transactions > disproportionate levels of business disruption
3. Reconciliation of data from returns to source (through a ‘reverse’ compliance process) will become the norm. Accuracy of data at source.
4. Will these trends and measures be extended in future to other transaction types (B2C sales and acquisitions) and other taxes/other processes/documents?
5. Will Member States be reasonable in introducing domestic e-invoicing with enough notice?
6. Removal of the requirement for customers to accept the e-invoices > Increased burdens on customers to identify any errors on e-invoices in time
7. Change to the e-invoicing definition > may impact the French e-invoicing mandate (hybrid PDF/A-3 invoice format with embedded XML)
8. Is the current EU e-invoicing EN 16931 standard adequate as a common scheme? Some sector specific details, multi-purchase order invoices etc. will be difficult to accommodate.
9. SMEs with a one VAT registration but sell cross-border within the EU in scope of intra-EU digital reporting
10. The European Commission has noet yet proposed regulations about transmission of data to the tax authorities (still unharmonized).
11. Will this proposal speed-up plans for introducing domestic obligations?
12. What level of intervention from the local tax authorities in the e-invoice exchange between businesses will occur in future? So far, the European Commission does not favour clearance models
Source: KPMG
