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Catching-up on E-Invoicing Developments – Part 1 – Middle East

Greetings from vatupdate.com! We trust you savored a rejuvenating summer interlude. As we transition into late August, a new chapter beckons. Brace yourself for an insightful series that unveils the kaleidoscope of transformations in the ever-evolving realm of E-Invoicing and E-Reporting.

Embarking with Part 1, we embark on a journey through the bustling Middle East, illuminating the freshest developments in this dynamic region. Stay tuned for knowledge that illuminates.


Bahrain is one step closer to implementing e-invoicing

  • The tax authority from the Kingdom of Bahrain, the National Bureau for Revenue, has released RFP (“Request for Proposal”) titled “E-invoicing central platform and maintenance”.
  • According to the RFP, the central platform would be “a system that receives and validates e-invoicing data obtained from businesses’ integrated e-Invoicing solutions”.
  • It is expected that NBR will implement e-Invoicing in Bahrain in the last part of 2024.

Egypt – Full implementation is expected to be completed by 2024

  • Egypt is moving towards mandatory e-invoicing as part of its Vision 2023 plan. The obligation stages are divided into different phases announced on various dates.
  • The first phase, covering 134 companies, began in November 2020,
  • followed by phase 2 in February 2021, covering 350 companies.
  • Phase 3 will require all remaining companies to enroll in the Large Taxpayers Centre by May 2021,
  • while phase 4 will make e-invoicing mandatory for all public sector entities by July 2021.
  • Phase 5 and 6 will begin in February 2022,
  • followed by phase 7 in June 2022 for certain taxpayers.
  • By July 2023, all taxpayers must enroll for e-invoicing and register with the tax authority.
  • Taxpayers must submit their e-invoices in XML or JSON format to the official e-invoicing portal, ETA, with a digital signature and archive period of seven years.
  • Egypt has also announced the e-receipt system for B2C transactions, with implementation beginning on July 1, 2022, for 153 initial companies.
  • By April 15, 2023, all companies must comply with the regulation.
  • Full implementation is expected to be completed by 2024.

Oman: E-Invoicing may be launched in April 2024, with mandatory implementation as of October 1, 2024

  • Oman is set to implement e-invoicing with a phased approach.
  • A voluntary launch period is planned between April and September 2024, followed by the mandatory implementation of e-invoicing starting from October 2024.

Saudi Arabia: 8 waves already announced, with the criteria of the 8th wave recently announced

  • Starting from December 4, 2021, all taxpayers subject to VAT in Saudi Arabia must issue, generate, and store e-documents, including invoices, credit notes, and debit notes. Electronic invoices must be generated and stored in structured data files, and paper or handwritten invoices, unstructured data files, PDF images, or scan copies of images are not considered e-invoices.
  • From January 1, 2023, all taxpayers must integrate into the ZATCA platform and send e-invoices in a defined structured format, following legal e-archiving requirements as per phase 1. ZATCA will implement this in waves based on taxpayer revenues.
  • The 8 waves already announced, with the criteria of the 8th wave recently announced.
    • Wave 1: taxpayers with an annual turnover of over SAR 3 billion are obliged from January 2023.
    • Wave 2: tax resident businesses with a turnover of over SAR 500 million will be mandatory from July 2023.
    • Wave 3: taxpayers with an annual income of over SAR 250 million will be liable from October 2023.
    • Wave 4: taxpayers with annual income between SAR 150 million and SAR 250 million will be liable from November 2023.
    •  Wave 5: From December 2023 is subject to all taxpayers whose VAT income for 2021-2022 exceeds SAR 100 million.
    • Wave 6: From January 2024, all taxpayers whose VATable income in 2021-2022 exceeds SAR 70 million will be obliged to issue e-Invoices.
    • Wave 7: From February 2024, all taxpayers whose income subject to value added tax in 2021 or 2022 exceeds SAR 50 million.
    • Wave 8:  From March 2024, all taxpayers whose VATable income exceeds SAR 40 million in 2021 or 2022.

United Arab Emirates – Plans have been published for mandatory B2B E-Invoicing in 2 phases (July 2025 and July 2026)

  • Recently, the UAE government has allowed the use of e-Invoices for transactions between the counterparties.
  • The E-Billing System project is being developed by the ministry of finance, which will automate the procedures for filing tax returns and improve tax compliance, thus reducing tax evasion.
  • The various phases are to be implemented and targets set to be completed by July 2025.
  • The UAE is likely to follow the Saudi Arabian model, which is based on the phased introduction of e-Invoicing for businesses of different sizes.

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