Worldwide updates on E-Invoicing/Real Time Reporting/SAF-T in November 2023

Worldwide Upcoming E-Invoicing mandates, implementations and changes – Chronological
Timeline of B2B E-Invoicing & E-Reporting mandates in the European Union

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Highlights

European Union – ViDA:
- The EU Parliament voted for a 1-year delay proposal to ViDA, this is not binding,
- It is looking forward to the Ecofin meeting of December 8, 2023 under the Spanish presidency.
- VATcalc reports that the ViDA proposal containing 3 pillarrs (DRR, Platform Economy and Single EU VAT registrations would be split. This is contrary to statements made by officials from the European Commission.
- The implementation of DRR would be delayed till 2030 or 2023.
- The proposals that would be implemented in 2024 will need to be postponed in any case given short time left till January 1, 2024.
- Contrary to the original proposals, during the IVA conference on Oct 19-20, Mr. Patrice Pillet (EU Commission) mentioned that Pre-clearance of invoice would be the cornerstone of E-invoicing & Digital reporting requirements. It is waiting what would actually be considered as ”Pre-clearance”. The imposotion of Clearance as part of ViDA may be to counterargue reservations from countries like Italy and Poland to approve the ViDA proposal.
- It will be looking forward to the Belgian presidency of the European Council how the ViDA proposal will develop. Concerns of business like the abolishment of the Summary Invoices and the 2+2 day reporting period of transactions seems to be reconsidered.
Belgium:More details are getting gradually released on E-Invoicing mandate in Belgium.
- Which transactions: B2B transactions between Belgian VAT registered taxpayers (with exceptions)
- Peppol will become the default standard for exchanging structured electronic invoices, unless agreed differently by both parties, but still following European Standard
- When: Per January 1, 2026 (no phased implementation)
- Draft legislation already approved by the Council of Ministers
- Derogation from the European Commission is pending
Croatia sent their request to derogate from the EU VAT Directive to the European Commission.
- Scope would B2B transaction between established taxpayers
- When: Per January 1, 2026
Estonia: B2B e-invoice mandate in accordance with the European e-invoicing standard
France issued a proposed timeline of the E-Invoicing mandate
- Implementation will occur in two phases for both E-Invoicing and E-Reporting
- September 1, 2026: Obligation to receive E-Invoices for all companies and Obligation to issue for large companies and mid-caps
- September 1, 2027: Obligation to issue for SMEs and micro-enterprises
- Deadlines may be delayed by one quarter if necessary
Germany would be implemening E-Invoicing mandate as of Jan 1, 2026 with a voluntary phase starting Jan 1, 2025. However, German Bundesrat calls for 2-year e-invoicing delay.
Greece Considers Potential E-Invoicing Mandate from 2025 to Support myDATA System.
Israel announced new deadline for first wave of e-invoicing mandate due to recent events. The first phase, initially planned for Jan 1, 2024 has been delayed till April 1, 2024.
Italy: Implementing mandatory E-Invoicing and E-Reporting will trigger new opportunities for tax authorities to verify the compliance of data reported. An example: Electronic invoices, electronic consideration and electronic payments: the data matching carried out by the Italian tax authorities.
Also Malaysia changed the timeline of the E-Invoicing mandate. Phased implementation will start now on August 1, 2024.
Poland’s Ministry of Finance has released a draft legislation proposing amendments to the country’s VAT return regulation, known as JPK_VAT. The changes are aimed at aligning the VAT return with the mandatory e-invoicing system, KSeF, and are expected to go into effect on July 1, 2024, alongside the e-invoicing obligation.
Romania: The President signed decree on fiscal-budgetary measures including electronic invoicing. For the timeline and scope: What is the timeline of the E-Invoicing mandate in Romania?
Spain: Timeline for implementation remains unclear. Failure to confirm a new government in Spain means the earliest launch date for its mandatory B2B e-invoicing regime may be pushed back as far as 1 October 2025.
Other countries making steps towards mandatory E-Invoicing: Mauritania, Mauritius, Montenegro, Slovenia, UAE and Zambia

Additional oberservation: Authorities will have an arsenal of potential checks available to them to verify the correctness of data and the reconciliation with other data reported to the authorities for accounting, direct tax (corporate tax return, TP documentation, Country by Country reporting, Pillar 2, …), indirect tax incl. VAT, Intrastat, Customs, Environmental and Employment Tax, …

AUSTRALIA

AUSTRALIA/ NEW ZEALAND