- The draft regulation of the Create and Grow Law has undergone many modifications and leaves many aspects open.
- It goes against the spirit and letter of a recommendation for electronic invoicing.
- The platform for exchanging invoices will only accept invoices in XML Facturae format, which goes against the European Union Implementing Decision 1870/2014.
- The regulation does not solve the problem of the directory of entry points for companies.
- The standard admits the use of CII and UBL formats, EDIFACT, and XML Facturae.
- Invoices sent through the Tax Agency platform have to be signed, which goes against the electronic invoice directive.
- The draft does not specify how the operators should connect, only that if they do not agree they will have to do it through the AEAT.
- Three mandatory states to communicate are established, but it is not obligatory to communicate the receipt.
- When the AEAT platform is used, a ministerial order for future publication must be referred to.
Source Sergio Ramon Ruiz Mahillo
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